GHG Emissions Reduction: ASI introduces flexibility to assurance framework; publishes Conformance tool
New rules for flexibility in the ASI assurance framework have been published, effective 1 January 2025.
5 December 2024
Key takeaways
- ASI remains committed to a 1.5ºC aligned aluminium sector.
- Acknowledging persistent structural barriers, new rules for flexibility in ASI’s Assurance framework have been published, effective 1 January 2025.
- This significant update, applicable only in very specific circumstances, allows Entities to maintain Certification even with long-running non-Conformances against GHG emissions reduction Criteria of the Performance Standard.
- In addition, ASI has released a Microsoft Excel based Criterion 5.3 Conformance tool, designed to improve consistency of Audits.
Watch an overview of the GHG Performance Exemption Rules
ASI’s commitment to driving change continues
ASI remains committed to a 1.5ºC aligned aluminium sector. The GHG emissions related Criteria of Performance Standard V3 (2022) are unchanged and the thresholds for Entity Conformance remain the same. ASI’s GHG Pathways Method continues to be the approach Entities are required to take in order to demonstrate alignment with a 1.5ºC trajectory.
Structural barriers to change will persist
However, the aluminium sector (as all sectors) is not reducing emissions in line with a 1.5ºC scenario , mainly due to structural barriers to change, beyond Entities’ control. For most, these barriers are unlikely to be overcome within the next 3-5 years. Hence, ASI will see repeated Non-Conformances related to 1.5ºC Pathways alignment within the next one to two certification cycles.
We estimate that up to 90% of ASI Certified smelters would be affected within the next 5 years, leading to a potential loss of Certification under the current Assurance framework. This could lead to reduced impact as these Entities would no longer be committed through their ASI Certification to work towards clear emissions reduction targets.
New Conformance Tool launched
The new Conformance Tool will help to ensure that the requirements of Criterion 5.3 are being Audited consistently both between Entities and with reference to the normative language of the Criterion.
This Microsoft Excel based checklist clearly defines the objective evidence required by each sub-criterion, with automated suggested conformance ratings based on the presence and quality of such evidence.
Tools such as this aim to address continued challenges with inconsistent interpretation and ASI plans to provided similar support for Auditing of other high priority Criteria in Q1 2025.
Introduction of exemption rules
To recognise this and to continue driving change at the sector level, while being transparent about these areas of Non-Conformance, ASI has designed specific ‘exemption’ rules around emissions reduction performance-related elements of Criterion 5.3 and Criterion 5.4. Exemption aims to maintain the integrity of the ASI Performance Standard and Assurance process, while allowing for flexibility under certain circumstances. This flexibility gives non-conformant Entities more time to address structural causes of Non-Conformance without risk of losing Certification due to these factors alone.
Under these exemption rules, Major Non-Conformance against Criterion 5.3a or performance related elements of 5.4 will not count towards the maximum three (3) Major Non-Conformances leading to Provisional Certification nor 3+ leading to non-issuance or revocation of a Certificate. At the same time, Exempted Entities are required to develop Corrective Action Plans and to demonstrate progress over time, while continuing to meet the other (articulation and disclosure-related) aspects of the GHG-related Criteria. Entities are encouraged to explore all Conformance avenues before relying on Exemption and Auditors directed to interrogate this action prior to granting Exemption.
Criteria 5.3a & 5.4 Exemption Process document
This document outlines new rules for flexibility (Exemption) within the ASI Assurance framework, specific to Criterion 5.3 and Criterion 5.4, that will recognise where there are structural barriers to conformance and allow non-Conformant Entities to maintain ASI Performance Standard Certification in specific circumstances.
Performance Standard Requirements
Under Criterion 5.3, Entities are required to:
- Establish and commit to a GHG Reduction Plan and Emissions Reduction Pathway, based on the ASI Method (“articulation”); and
- Demonstrate they are reducing emissions in line with this Pathway (“performance”).
In summary; Entities should:
- Set a baseline year
- Use the ASI GHG Pathways Method to derive targets (long and short term) for reduction of GHG emissions intensity in line with a 1.5ºC trajectory (the first Intermediate Target to be set no later than 5-years from the baseline year)
- Annually review the plan and performance against it
- Publicly disclose the plan and performance against it
- Put in place and use the necessary management systems (as described in criterion 5.4) to achieve the GHG emissions reduction targets
- For Audits occurring 3 or more years after the baseline year, Entities need to show they are following their Method-derived Pathway, at least on average over the prior Certification Period.
Entities that are unable to demonstrate (6) would be eligible for Exemption under the newly published rules.
What does this mean for Entities?
If your next (re)-Certification audit is at least 3 years after your baseline year, then ensure your Auditor is aware of the new Exemption rules.
If you are unable to demonstrate emissions reduction in line with the 1.5ºC Pathway your Auditor will issue you with non-Conformances on the relevant criteria. However, if you fall into a specific category where this is due to structural barriers (outlined in the rules) this non-Conformance alone will not impact your Certification Status. You will have an extended timeline to address the non-Conformances and will be asked to monitor and report progress annually (in line with the disclosure expectations of Criteria 5.1 and 5.3).
What does this mean for Auditors?
A) Exemption
Auditors should ensure they are aware of the Exemption Conditions for 5.3 and 5.4 and the responsibilities of Entities, Auditors and the Secretariat:
1) ASI Entity
- Providing the Auditor Objective Evidence that it meets each of the conditions for Exemption
- Developing (long-term) Corrective Action Plans for the applicable Non-Conformances
- Continuing to disclose GHG emissions performance publicly and annually
2) Lead Auditor
- Determining a Conformance Rating against the normative requirements of the Standard
- Interrogating Objective Evidence that the Entity meets the criterion for Exemption
- Applying an Exemption, if appropriate
3) ASI Secretariat
- Defining Exemption conditions and process and ensuring these are followed during Audits
- Providing technical oversight, training and resources
- Issuing Certificates accordingly
- Communicating clearly to stakeholders that an Exemption has been applied
B) Conformance Tool
While use of the tool is not required for ASI Audits, it will be used in Oversight to check Auditors’ ratings are aligned with the evidence presented, so Auditors (and Entities) are encouraged to use it when planning for and carrying out Audits against Criterion 5.3.
More information
For further information please contact chris@aluminium-stewardship.org
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