UCO Due Diligence: What Auditors Should Actually Test – Insight 3

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A supplier certificate is important – but it is not enough.

For Used Cooking Oil, effective due diligence should test whether the physical supply chain and the paperwork tell the same story.

1. Points of Origin

Do the Points of Origin exist? Does their activity genuinely generate the type of material being claimed? A restaurant, hotel kitchen and industrial food processor may all generate waste oils, but not necessarily the same regulatory feedstock.

2. Declared volumes

Do the volumes make sense? If a collecting point reports a significant increase in UCO but the number of collection sites has barely changed, there should be an explanation supported by evidence.

3. Certificate status and scope

Is the certificate genuine, valid, within scope and appropriate for the material being supplied? A certificate covering one activity does not automatically validate every material a business trades.

4. Material classification

Does the evidence actually show why the material qualifies as UCO? An oil does not become UCO simply because it came from the food sector or is being sold for biofuel production.

5. Mass balance

Do the numbers reconcile? Certified outputs should be supported by sufficient eligible inputs. Unexplained variances, unusual stock movements or repeated corrections can indicate that the physical supply chain and the records are not aligned.

6. Supply-chain changes

Unexpected changes should trigger additional review, including sudden increases in volume, new countries of origin, supplier changes, changes in feedstock description or new processing routes.

7. Third-country UCO requirements

Commission Regulation (EU) 2025/2181 introduces new requirements from 19 November 2027 for certain UCO imported into the EU from third countries where the material falls within Category 3 Animal By-Products rules. Operators should begin checking whether relevant establishments will have the appropriate approval or registration and whether shipment documentation will align with those details.

The key test

Origin + classification + volume + documentation + mass balance should all tell the same story.

Geovitia can help organisations advise on, implement and manage those controls.