by Grecia Maya & Rachel Ford

The Low Carbon Fuel Standard (LCFS) July 1st, 2025, amendments significantly expanded the sustainability and traceability requirements for many crop- and forestry-based biomass feedstocks. Pursuant to §95488.9(g)(1-8), annual third-party verification will now include requirements for pathway holders to substantiate feedstock eligibility and maintain chain-of-custody records. The new requirements introduce geographic documentation, plot-level attestations, and third-party sustainability certification, which will require closer coordination between farmers and fuel producers. These obligations will be implemented in stages across the 2026, 2028, and 2031 reporting years, creating a new compliance challenge across the biomass supply chain. It is important to note that third-party sustainability certification should not be confused with LCFS third-party verification, as the two processes serve distinct functions.

A great way to see how these new regulations will affect supply chains is to consider the soybean oil to renewable diesel pathway. Certification of eligible feedstocks must be documented throughout the transfer process to the fuel producer consistent with the timeline outlined below.

All biomass, with the exception of specified-source feedstocks listed under §95488.8(g)(1)(A),
are subject to §95488.9(g)(1-3) amendments. This includes:

• crop-derived oils
• grain and starch feedstocks
• sugar feedstocks
• some agricultural fibers and residues
• forest-derived biomass

Using the same example, conventional soybean oil is subject to these sustainability requirements, whereas used cooking oil is exempt and instead subject to the specified-source feedstock requirements under §95488.8(g). This distinction shows how a feedstock’s source and use history can determine its regulatory compliance requirements.

For biomass to be considered eligible, and the associated renewable fuel to generate the expected LCFS credits, it must originate from land that meets the eligibility requirements established under §95488.9(g)(2). Eligible land must have been cleared or cultivated before and actively managed or fallow since January 1st , 2008. Additionally, the biomass sourced from the land must be cultivated and harvested in accordance with local, state, and federal rules. If the
crops are grown on land that does not meet eligibility requirements, the renewable diesel produced from the associated crop-derived oil will be assigned an applicable fossil-fuel CI in compliance with §95488.9(g)(4). This may result in generating deficits rather than generating credits. For example, if soybeans are not grown on eligible land, the renewable diesel product associated with the soybean oil will be assigned to the ultra-low sulfur diesel (ULSD) CI value from Table 7-1 in §95488.5(e).

The critical change for crop-based biomass is the requirement to prove eligibility of agricultural origin, which falls 100 percent on the pathway holder, but likely originates from the farmer. The following documentation and attestation can be provided to prove agricultural origin eligibility:

• Geographical screening using the land eligibility test, which can compare the supply
  plots against historical imagery and farm records.
• Geographical shapefiles, which are coordinates of the eligible crop-growing plot
  boundaries.
• A biomass sourcing area, which can help identify eligible feedstock sources. Utilization
  of a sourcing area map can establish an area of sourcing field boundaries with eligibility
  clearly marked for third-party verification.
• Historical land-use data to back up land eligibility conclusions.

Pathway holders must collaborate with farmers to ensure that the documentation, records, and attestations required under §95488.9(g)(5) are maintained and readily available for third-party verification.

Establishing eligible land is only the first step toward compliance. Pathway holders must demonstrate eligibility of qualifying biomass. From a verifier’s perspective, the main challenge pathway holders will face is connecting eligible land to the actual quantity of biomass claimed. Throughout the supply chain, §95488.8(g) requires chain-of-custody evidence and certification, along with accurate volume or mass measurements from the first gathering point to the fuel
producer.

For third-party verification, pathway holders must connect evidence of eligibility and origin to the actual quantity of biomass claimed. Supplier attestations are essentially farm declarations that support claims of biomass origin and eligibility but cannot independently substantiate quantity. Farm and plot records also help establish crop production quantities and actual acreage harvested but alone cannot prove quantity. Purchase and delivery records can quantify transfers between suppliers and subsequent stages of the supply chain but do not independently connect quantity to origin.

Compliance Challenges: Connecting Quantity to Origin

Quantity reconciliation is the crucial link for connecting eligible biomass to eligible feedstock volumes. Appropriate conversion factors must be applied to accurately account for soybean oil production from raw soybeans. A third-party verifier will assess the yields, process losses, and production documentation to support these claims. However, there is a difference between regional screening and substantiating the volume claimed. Screening can help evaluate land eligibility or potential land-conversion risk. For example, if 75 percent of a soybean farm meets the land eligibility requirements, it does not necessarily mean that 75 percent of the harvested soybeans qualify as eligible biomass. To prove quantities, documentation of exact volume or mass measurements must be recorded at each supply chain phase. Note that CARB does not require eligible biomass to be stored and transported separately, provided that eligible quantities are properly reconciled through mass balance.

Eligibility survives aggregation when it can be tracked using the acceptable methods as described in the regulation. When eligible and ineligible feedstocks are mixed, the supplier must maintain records showing how much eligible feedstock has entered and left the facility. Eligible feedstock amounts cannot increase when it changes ownership or passes through another facility. The updates to the regulation highlight how physical separation is not required, but the eligibility attribute must be traceable.

Mass balance procedures, chain-of-custody documentation, and double-counting controls support reported feedstock quantities. These controls should be established before submitting annual or quarterly data to CARB to prevent nonconformances during third-party verification. Fuel reporters can compare supplier-reported shipments with quantities received at the fuel production facility to identify discrepancies between upstream claims and actual deliveries. They can also cross-check CI models to compare feedstock consumption against fuel production and expected conversion yields, identifying any potential discrepancies in reported feedstock consumption.

The first gathering point is critical because it receives, aggregates, stores, or treats biomass directly from farms before distributing or further processing. Feedstock quantities documented at the first gathering point form the basis of biomass accounting and must be tracked through the supply chain to the fuel reporter.

Biomass Sustainability Requirements Rollout Timeline

Section §95488.9(g)(5)-(7) outlines a phased implementation schedule for the biomass
sustainability requirements.

2026 Data Year – Geographic Information and Attestations

Beginning with the 2026 data year (reported in 2027), existing fuel pathway holders using applicable biomass must maintain attestations and submit geographic shapefiles or plot boundary coordinates identifying where the biomass was produced. New fuel pathway applicants have been subject to these requirements since July 1, 2025, consistent with CARB’s implementation guidance for biomass sourced before the amendments became effective. The required attestation under §95488.9(g)(5)(C) must be signed by an authorized officer of the fuel pathway holder or applicant. Although full sustainability certification is not yet required, pathway holders should begin coordinating with suppliers to obtain the supporting land records and geographic information needed to substantiate these attestations.

For example, a renewable diesel producer using soybean oil can establish a supplier traceability program to collect supporting documentation from soybean suppliers. The fuel producer can coordinate with soybean crushing facilities and aggregators to collect farm-level information and evaluate the completeness of supplier records. Early coordination will help identify documentation gaps before the more extensive requirements take effect in 2028.

2028 Data Year – Land Eligibility Certification and Chain of Custody

Beginning in the 2028 data year (reported in 2029), existing fuel pathway holders must meet the biomass sustainability requirements under section §95488.9(g)(2) and maintain continuous third-party sustainability certification under a CARB-approved certification system. New fuel pathway applications must meet these requirements beginning January 1, 2028.

It is important to distinguish between a CARB approved sustainability certification system and LCFS third-party verification, as they serve different purposes and compliance requirements. A CARB approved sustainability certification system evaluates whether feedstocks meet applicable biomass sustainability requirements, including land-use and traceability criteria (e.g. certification systems recognized by the European Commission for the European Union Renewable Energy Directive). In contrast, LCFS third-party verification focuses on independently assessing the accuracy, completeness, and regulatory compliance of fuel pathway applications and reports, including CI calculators and supporting documentation. While both processes provide independent oversight, sustainability certification does not replace LCFS third-party verification.

At this stage, chain-of-custody documentation must satisfy §95488.8(g)(1)(B)1-3, and certificates specifying the quantity of eligible biomass must accompany the material from the feedstock first gathering point to the fuel producer. These records must be available for review by the third-party verifier and CARB. Geographic boundary records must also be retained, although CARB no longer requires routine shapefile submissions once third-party sustainability
certification is completed.

To illustrate these requirements from a verifier’s perspective, consider the following example:

A soybean crushing facility receives 10,000 metric tons (MT) of soybeans, consisting of 8,000MT of eligible soybeans and 2,000 MT of ineligible soybeans. Assuming a 20 percent oil yield, the facility produces 2,000 MT of soybean oil, of which 1,600 MT could be attributed to eligible soybeans.

However, the 1,600 MT estimate must be supported by mass-balance accounting, conversion factors, and chain-of-custody documentation. To avoid non-conformances, the fuel producer could require monthly summaries from the crushing facility showing eligible soybean receipts and soybean oil quantities assigned to each transfer. Fuel producers should reconcile these quantities before assigning eligible attributes to soybean oil used in renewable diesel production to reduce the risk of overclaiming.

2031 Data Year – Full Sustainability Requirements

Beginning with the 2031 data year (reported in 2032), existing pathway holders must meet the full biomass stainability requirements under section §95488.9(g)(2) and (3). New fuel pathway applications must meet these requirements beginning January 1, 2031.

In addition to land eligibility and chain-of-custody evidence, biomass must use the best environmental management practices that reduce GHG emissions or increase GHG sequestration. These include maintaining a biodiverse habitat, improving soil management, minimizing fertilizer runoff, and reducing unsustainable water use. The following example illustrates how these requirements may affect a fuel producer: A renewable diesel producer purchases soybean oil from three independent crushing facilities:

• Supplier A maintains full sustainability certification and supplies 6,000 MT of soybean oil
  annually.
• Supplier B maintains sustainability certification covering land eligibility and supplies
  3,000 MT of soybean oil annually.
• Supplier C has expired sustainability certification and supplies 1,000 MT of soybean oil
  annually.

Although the fuel producer purchases 10,000 MT of soybean oil, not all of it meets the 2031 sustainability certification requirements. Supplier A’s 6,000 MT could qualify, provided the quantities are supported by valid certification and chain-of-custody records. Suppliers B and C would need to address their certification deficiencies before their feedstock can be considered compliant.

To manage these risks, fuel producers should confirm that suppliers are certified under an approved certification system prior to purchasing feedstock. During the reporting year, the fuel producers should monitor certification status and reconcile quantities against delivery records to avoid potential non-conformances.

Supply Chain Preparation and Verification Considerations

Fuel producers have a financial incentive to ensure farmers and upstream suppliers maintain adequate feedstock records. Verifiable documentation helps protect feedstock eligibility, supports carbon intensity determination, and reduces the risk of unsupported feedstock quantities.

The complexity of biomass tracking and traceability increases when the feedstock supply chain involves multiple unrelated entities. Additional documentation and verification procedures may be necessary to support feedstock claims. From a verifier’s perspective, obtaining records from multiple independent entities can be challenging and increase the risks of overclaiming or double counting. Establishing standardized accounting and recordkeeping procedures across the supply chain can help prevent false feedstock claims and improve traceability during annual third-party verification.

Conclusion

The biomass sustainability requirements establish an evidence chain from the field to the final fuel claim, supported by geographic screening, supplier records, mass balance, and third-party sustainability certification. Biomass must originate from eligible land, supported by geographic documentation and pathway-holder attestations. Chain-of-custody records must track the eligible biomass volumes from the feedstock first gathering point to the fuel producer.

All entities in the feedstock supply chain play a critical role in maintaining accurate records for third party verification. Verifiers will assess records to confirm proper attribute accounting and consistency with certified CI data. Proactive coordination with farmers and suppliers will help fuel producers meet these requirements and achieve successful verification outcomes.