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From Hotel Kitchens to Jet Fuel: ISCC’s New SAF Book-and-Claim Rules Meet Thailand

On 5 October 2026, Bangchak signed a memorandum with Thailand’s Ministry of Tourism and Sports, DASTA, the Thai Hotels Association and the Thai Restaurant Association to collect used cooking oil from hotels and restaurants as feedstock for sustainable aviation fuel. Nine days later the group said its 1-million-litre-a-day SAF unit is running at full capacity, supplying customers in Europe. And in between, ISCC — the certification scheme most of Thailand’s SAF supply chain already sits inside — put into force its first rulebook for selling SAF without moving the fuel.

Put together, those three developments change who is in Thailand’s SAF supply chain, and how far its paperwork has to travel. Here is what each one actually says, what it does not, and what it means for the Thai companies now inside the chain.

1M L/day
BSGF SAF unit, now at full capacity (Bangchak, 14 Oct 2026)
70–80%
share of SAF production cost that is feedstock
1t
of neat SAF = one ISCC claim certificate (TIEC)
24mo
recommended maximum TIEC validity

Three dates in three weeks

22 September 2026 — ISCC. ISCC released its Guidance Document — Book and Claim of Sustainable Aviation Fuel (v1.0, valid from 22 September 2026) across ISCC EU, PLUS and CORSIA, alongside an updated Credit Transfer System document that adds a new “Facilitator” role. The same batch of system updates set 22 October 2026 as the last day the offline Word version of the ISCC CORSIA audit procedures may be used — after that, all ISCC CORSIA audits must run in ISCC’s online audit procedure system (APS).

5 October 2026 — Bangchak and the tourism sector. Under its Fry to Fly initiative, Bangchak, the Department of Tourism, DASTA and the two trade associations agreed to organise systematic used-cooking-oil (UCO) collection from hotels and restaurants, and to campaign against re-using frying oil. The release gives no volumes and no number of participating venues.

14 October 2026 — full capacity. Bangchak said BSGF’s HEFA-SPK unit is running at full capacity for European customers “where SAF mandates are in place”, that feedstock is 70–80% of production cost, and that it is exploring certified sustainable palm oil, palm fatty acid distillate (PFAD) and palm-oil-mill-effluent feedstocks. It called on the government to set clear SAF targets and a roadmap.

What ISCC’s book-and-claim guidance actually allows

Until now, a SAF claim generally travelled with the physical fuel under a mass-balance chain of custody. Book-and-claim decouples the two: the fuel is used wherever it is cheapest to deliver, and the environmental attribute is sold separately as a registry certificate. ISCC calls that certificate a TIEC — a transferable instrument with entitlement to claim — equal to one metric tonne of neat, certified SAF.

Mass balanceBook and claim (ISCC v1.0)
What travelsFuel and its sustainability claim togetherThe claim, as a registry certificate (TIEC)
Who can registerEach certified holder passes it onOnly the SAF supplier registers TIECs
Upstream chainFully certifiedFully certified up to the entry point
Going backn/aNo — once decoupled, never back to mass balance
ClaimsPer scheme rulesOne Scope 1 claim per TIEC; Scope 3 may be co-claimed

The rules that matter most for a Thai supplier, read from the guidance itself:

Full certification upstream

Book and claim is excluded “until the entry point” — every link before it, down to the UCO collector, must already be certified (§5.1).

Additionality

Volumes used to meet a mandate — the guidance names EU ETS and UK RTFO — are not eligible unless that regulation allows it (§5.3.1).

One-way door

Once a batch enters book and claim, the physical fuel can only be traded on as conventional jet fuel (§3.2, §5.3.1).

Who claims what

Only aircraft operators make Scope 1 claims; logistics providers and corporate end-customers make Scope 3 claims (§6.1, §6.4).

The commercial significance is the last point. A Scope 3 buyer — a freight forwarder, a shipper, a corporate with a business-travel footprint — can now buy a Thai-made SAF attribute under a published ISCC rulebook without the fuel ever reaching its route. That widens the buyer pool for a plant selling a commodity whose cost is mostly feedstock.

Book and claim does nothing to loosen the front of the chain. If anything it raises the stakes, because a claim sold to a European airline or a multinational’s Scope 3 inventory now rests on every upstream record being right. For UCO, that chain starts in a kitchen.

1
Point of origin
Hotel or restaurant kitchen. Signs an ISCC self-declaration that the oil was used to cook food for human consumption and is a waste.
2
Collecting point
Certified collector. Holds the self-declarations, delivery notes and weighbridge records; runs the mass balance.
3
Processing unit
SAF refinery. Certified; converts UCO via HEFA and issues sustainability declarations.
4
SAF supplier
The only party that may register TIECs, for batches in its chain of custody within the last 12 months.
5
Claimants
Airline retires the Scope 1 claim; shippers and corporates retire Scope 3.

ISCC’s template self-declaration for UCO points of origin defines UCO as “oil and fat of vegetable or animal origin which has been used to cook food for human consumption,” and states that auditors can examine the declaration on-site or by contacting the signatory. A hotel that signs one is no longer just disposing of waste oil; it is a named, auditable source in an export chain. ISCC’s own certificate database shows how much of Thailand’s book is already built around that chain: on 16 October 2026 it listed 205 valid Thai certificates — 103 ISCC PLUS, 70 ISCC EU and 32 ISCC CORSIA.

112
valid ISCC CORSIA certificates, Indonesia
68
Singapore
32
Thailand
27
Malaysia

Valid ISCC CORSIA certificates by country, queried from the ISCC certificate database on 16 October 2026. Counts move daily as certificates expire and renew.

Singapore is about to become a buyer next door

The nearest new buyer is not in Europe. Singapore’s Civil Aviation Authority began collecting its SAF levy on tickets sold from 1 October 2026, for flights departing from 1 January 2027 (the cargo levy was deferred by a year). CAAS says its procurement company, SAFCo, plans to issue a request for proposals for SAF by the end of 2026, with first uplift expected in mid-2027, and that procurement will comply with sustainability requirements including CORSIA Eligible Fuels certification standards. ISCC CORSIA is one of the routes to that certification — which is why Thailand’s 32 CORSIA certificates matter more than their number suggests.

Where the evidence runs out

Three honest limits, because overclaiming here would be easy:

  • Bangchak’s releases do not mention ISCC. They say the SAF is made “in accordance with international standards”. We are not claiming which certificates BSGF holds or which scheme its European sales use.
  • Thailand has no legal SAF blending obligation. The 1%-to-8% ladder in circulation sits in draft national energy plans that had not been approved as at our last check; DOEB’s aviation-fuel specification and the CAAT airline MOU are voluntary in effect. Bangchak’s own call for “clear targets and a roadmap” says the same thing.
  • Feedstock choice changes which market counts it. UCO sits in Annex IX Part B of the EU Renewable Energy Directive and counts toward ReFuelEU’s minimum shares; ReFuelEU Art. 4(5) excludes PFAD unless it is listed in Annex IX. A PFAD-based SAF may still have voluntary and Scope 3 buyers, but it is not a like-for-like substitute for a UCO-based one in the EU mandate market.

And on language: ISCC does not require an operator’s own records to be in English, and it publishes self-declaration templates in many languages. What its rules do say — ISCC PLUS 103, §4.2 — is narrower:

Regardless of the language in which the audit was conducted, the audit report shall always be written in English.

ISCC PLUS 103 v1.1, §4.2, footnote 4

So the documents that leave Thailand — the audit report, the sustainability declarations a European or Singaporean buyer reads, the parent company’s sustainability disclosure — end up being read in English by people who cannot check the Thai original. That is the same pattern we see on the listed side: FTSE Russell scores from public disclosure with no questionnaire, Thai is not among the six key research languages in its ESG FAQ (§1.8), and SET recommends — it does not require — that listed companies disclose in English because FTSE assesses primarily from English. The point is not a penalty for Thai. It is that the English version is the one the buyer and the analyst actually read, so its accuracy is worth controlling. More on what FTSE Russell reads →

What Thai producers, collectors and buyers should do now

Key takeaways
  • Collectors: treat every new hotel or restaurant source as an auditable point of origin — signed self-declaration, delivery notes, weighbridge records — before the first litre moves.
  • CORSIA-certified sites: the offline audit forms end on 22 October 2026; make sure your next ISCC CORSIA audit is scheduled in APS.
  • SAF producers: decide batch by batch whether volume goes to mass balance or book and claim — the guidance makes that choice irreversible.
  • Scope 3 buyers: check that a SAF certificate is registered by the SAF supplier, is within its validity, and has not also been counted toward a mandate.
  • Listed parents: make sure the English sustainability disclosure describes the SAF chain exactly as the certificates do — feedstock, scheme and claim type.

Preparing a Thai site for ISCC?

Othello provides ISCC EU, PLUS and CORSIA preparation, training and audit support — gap assessment, mass balance and internal assessment — and the ISO 17100 English edition of the documents your buyers read. We are not a certification body.

See ISCC certification support

For the audit mechanics behind the certificate itself, see our ISCC audit preparation guide; for the carbon numbers that sit beside a SAF claim in a sustainability report, see TGO CFO certification; and for why translation drift becomes a disclosure risk, see ESG translation risk and our technical translation practice. EU-facing exporters should also track CBAM, the one EU regime that requires the emissions report in English by law. All dates are tracked on our ESG regulatory tracker.

Sources: ISCC, Guidance Document — Book and Claim of Sustainable Aviation Fuel v1.0 (valid from 22 Sep 2026) and ISCC system updates of 22 Sep 2026 (iscc-system.org); ISCC PLUS 103 v1.1; ISCC CORSIA self-declaration for UCO points of origin; ISCC certificate database (queried 16 Oct 2026); Bangchak Corporation news releases of 6 Oct and 14 Oct 2026; Civil Aviation Authority of Singapore release of 3 Sep 2026; Regulation (EU) 2023/2405 (ReFuelEU Aviation) Art. 4(5); FTSE Russell ESG Scores and Indices FAQ v1.5 §1.8; SET FTSE Russell Q&A item 16.

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