BioLedger wants to regain trust in sustainability reporting

opinion

by Fayaz Hussain

December 1, 2025

Consider this hypothetical situation. A trader with an office and sustainability certificate receives a 15,000-tonne shipment order for crude palm oil priced around $1,000 per tonne. But instead of labelling it as CPO, he calls it palm oil mill effluent (POME). The value of the same shipment almost doubles because exporters save taxes, duties while getting high prices for the now-labelled feedstock. The monetary benefit of doing this can reach millions of dollars but the effort required is minimal: just changing a few letters on declaration form.

The International Sustainability and Carbon Certification, Transport & Environment and Environmental Investigation Agency have raised concerns over the ‘alarming’ rise in fraudulent palm oil products being imported into the EU to make biofuels.

For Patrick Lynch, founder of BioLedger, this isn’t hypothetical. This fraud in reporting is what drove him to build a digital traceability platform which now processes over 150,000 tonnes of biofuel feedstock each month. This includes used cooking oil, fats and agricultural oils.

Lynch has spent over 15 years in biofuel supply chain. He served nearly a decade as head of compliance for UK-based supply chain management company Greenergy. “When things happen on paper and in Excel, it’s so easy to hide pieces of paper or not show one Excel file,” he tells SAF Investor. “The traders are always 10 steps ahead of the auditors.”

He designed BioLedger as a digital alternative to paper-based certification systems. The concept was approved by the European Commission which mandated digital traceability in 2022. This served as the precursor to the European Commission’s Union Database – a central ledger for all biofuel transactions in the continent.

BioLedger’s key innovation was to create a “digital twin” for every physical consignment moving through the supply chain. For a feedstock like used cooking oil, a critical feedstock in SAF production, the trace starts with mobile application that collectors use to record pickups from restaurants.

Apps equipped with geo-fencing ensure drivers are at least within the 500 metre range of the restaurant when reporting a collection. As an added layer of transparency, they are also required to obtain signatures and photographs from restaurant staff. This is to prevent false collections from someone sitting at home on the sofa creating fake collections, says Lynch.

For agricultural feedstocks such as ethanol used in the alcohol-to-jet pathway, lands are monitored to ensure the area was already agricultural in 2008 to verify no deforestation was carried out to produce the crop for ethanol.

Even though BioLedger was founded to be used in tracing feedstocks for road biofuels, Lynch says the platform is extremely relevant to SAF.

“In terms of SAF, it’s all the same supply chain,” explains Lynch. “SAF is produced by existing companies making HVO and co-processed fuel, and the feedstocks are the same – used cooking oil, food waste, palm oil mill effluent. It’s all the same supply chains that have been supplying road fuel for the last 15 years. So they have the same problems and the same solutions.”

Since the feedstocks are broadly the same, so are the fraud vulnerabilities. Lynch highlights the curious case of never ending supply of used cooking oil which suggests adulteration. “There’s never been a point where the industry has said ‘stop, we haven’t got any more.’ That demonstrates new volume isn’t coming from people making more used cooking oil. When it becomes expensive enough, it pulls in things that look like used cooking oil but aren’t – category three tallow, palm fatty acids, or virgin vegetable oils are fraudulently relabelled.”

BioLedger operates in Europea and US. While Europe relies on certification systems with minimal liability, the US approach puts all liability on biofuel producers who can face millions in fines if feedstock fraud is uncovered. This approach makes US supply chains much more transparent forcing producers to demand more visibility into the supply chain.

The platform accommodates both approaches. However, the US in January 2025 excluded all non-domestic used cooking oil from US mandates. The US government gave insufficient trust in international traceability as the reason for this exclusion.

“They only excluded it because they don’t trust systems based on pieces of paper moving through the supply chain,” says Lynch. But he warns this approach is short-sighted. Instead he suggests being more stringent in sustainability reporting requirements. “There are billions of people outside the US producing waste that can be used to supply biofuel mandates. Why exclude that sustainable volume?”

But as SAF production grows, traceability of feedstocks provides the trust infrastructure the industry requires. For Lynch, BioLedger’s premise is simple: you can’t fight million dollar fraud incentive with paperwork. You need transparency.