Five or Ten Tonnes? Point-of-Origin Audit Triggers, Global Used Cooking Oil Trade,

Abstract

Used cooking oil (UCO) has become a strategically important feedstock for hydroprocessed esters and fatty acids (HEFA)-based sustainable aviation fuel because it combines technological maturity with the circular-economy appeal of recovering a waste lipid. Its climate value, however, depends on whether the feedstock is genuinely used oil, accurately quantified, traceable to its point of origin, and protected against duplication or substitution. This qualitative literature review examines differences between the point-of-origin requirements of International Sustainability and Carbon Certification for the European Union and for the Carbon Offsetting and Reduction Scheme for International Aviation. It clarifies that the frequently cited 5- and 10-metric-tonne figures are not limits on trade, certification eligibility, or SAF production. They are risk-based triggers determining which non-individually certified points of origin enter the population for sample-based on-site auditing. ISCC EU applies a 5-tonne monthly or 60-tonne annual trigger based principally on volume supplied, whereas the publicly accessible ISCC CORSIA provisions apply a 10-tonne monthly or 120-tonne annual trigger based on volume generated. The lower EU trigger potentially strengthens fraud deterrence and market confidence but enlarges the audit population, increases transaction costs, and may disadvantage fragmented suppliers. The higher CORSIA trigger supports proportionality but leaves more medium-sized generators outside routine on-site sampling. The article concludes that interoperability, persistent point-of-origin identifiers, cross-collector volume aggregation, digital traceability, plausibility testing, auditor competence, and transparent national UCO balances are more important than numerical harmonization alone.