INS compliance, from inbound declaration to GSE-ready filing
FuelFWD ingests the Italian Annex 1 declarations your suppliers send, runs them through your standard mass balance and validation flow, and outputs the correct Annex 1 model for every outgoing consignment plus a complete monthly GSE package. Batch codes composed correctly the first time, cumulative GHG in the right unit, upstream identifier chain intact.
The gap
What the rule asks for vs. what spreadsheets deliver
What the INS requires vs how operators still build it
The Italian National Scheme, established by the decree of 7 August 2024, replaced the 2019 regime and widened the perimeter to biomass fuels for power and heat, RFNBO and recycled carbon fuels. It runs on prescribed forms and fixed clocks:
- Seven prescribed models, not one: Parts A, B, C, D, E*, E** and F, selected by chain position and fuel type, each with a different field set
- A unique batch code embedding both the certification body’s identifier code and the operator’s own
- Cumulative GHG from Part C onward, restated in the unit of the product leaving your phase, with emissions before waste generation counted as zero
- The upstream identifier chain for all previous phases, or the immediately preceding phase plus a traceability self-declaration, with full reconstruction possible at audit
- Mass balance lots of 12 months for farms and first collection points, 3 months for everyone else, and 1 to 6 months for anaerobic digestion, redefined whenever the feedstock diet changes
- Two-timestamp validity: every operator in the chain must have held a valid certificate both when they issued their document and when the batch was dispatched
- A monthly DSAN to GSE per CENSIMP plant and per production unit, for incentivised power and heat producers
Why email, PDFs and a spreadsheet stop holding at volume
Most Italian operators run this on email, PDFs and an internal spreadsheet. The same failure modes appear as volume grows:
- Supplier certificate lapses go unnoticed until an auditor checks issuance and dispatch dates against the GSE register
- Scope breaches are silent: a product category or storage location outside the certificate invalidates the declaration, and nothing about the document looks wrong
- Part B zeros get filled in. Emissions before waste generation are genuinely zero; treating them as missing data overstates the whole downstream chain
- Incentive segregation is not modelled. Article 12(10) bars mixing incentive-eligible and non-eligible feedstock before final transformation, and before the digester for biomethane
- Attachments drift. CER codes, the article 184-bis by-product declaration, SOA traceability with the category 1 and 2 fat statement, and the extra-EU waste declaration each travel with the batch and each expire on their own schedule
- Documents get edited. Article 9(14) forbids modifying an issued declaration except to correct a material error, and a critical non-conformity can annul declarations retroactively
How FuelFWD turns Annex 1 documents into a controlled chain
Three capabilities that take you from the declaration a supplier emails you to the package your signatory files with GSE.
Italian forms in, structured data out
Inbound Annex 1 declarations are ingested with the batch code, supplier certificate number and last audit reference, feedstock category, place of origin, transport document, ILO conventions and the full GHG breakdown across Eec, Ep, Etd, Ei, Esca, Eccs and Eccr. No retyping.
Standard flow, INS output
The platform runs your usual mass balance and validation steps, then generates the correct Annex 1 model for the consignment: Part C for an intermediate phase, Part D when you are last in the chain and transferring to the fornitore, with cumulative GHG restated in the unit of your outgoing product.
Validity and scope enforced before issue
Every upstream certificate is checked at both timestamps. Product category and storage location are checked against your own certified scope. Incentive-eligible feedstock is held apart from non-eligible material as a hard constraint, not a warning after the fact.
Who uses this
Built for the roles that own the obligation
Questions about INS compliance
- No, and no software can. Access to the CDS portal is exclusively via SPID, which is issued to natural persons rather than companies, and the monthly filing is a DSAN under DPR 445/2000 carrying personal liability. FuelFWD prepares and validates the complete package; your authorised signatory reviews and submits.
- The one matching your chain position and fuel type. Part A for cultivation or forest harvest, Part B where waste or residue originates, Part C for intermediate phases, Part D when you are last in a non-biogas chain, Part E* and E** at the digester, Part F for biomethane or power and heat produced by a party other than the digester operator.
- Emissions up to and including generation of a waste, residue or by-product are treated as zero, so only transport carries forward. The zero is recorded as a real value, not a blank, and the CER code or extra-EU waste declaration travels with the batch as an attachment.
- Every consignment is tested against the supplier’s certificate at both issuance and dispatch. Batches falling outside a valid window are flagged before you issue anything downstream, rather than after an auditor finds them.
- Yes, and article 7(8) requires it. Operators in more than one scheme must expose all volumes and GHG values, inbound and outbound, to any auditor regardless of which scheme is under audit. FuelFWD holds one ledger with the scheme as an attribute and reconciles per-scheme volumes against total physical throughput.
- Yes, append-only with full version history. Issued declarations cannot be silently edited, and where a critical non-conformity upstream annuls documents retroactively, affected batches are traced through the chain.
Related use cases
Keep exploring how FuelFWD handles compliance
Ready when you are
See your own Annex 1 declarations become a GSE package
We’ll load real inbound declarations from your operation into a FuelFWD environment and walk through Annex 1 generation and the monthly GSE package, end to end.