Product-level Greenhouse Gas Emission Report

Greenhouse Gas Emission Report for Co-processed Products

Report No.: #GHG-IY26205 Reporting period: 2025-01-01 ~ 2025-05-31 (151 days) Issue date: 2026-05-15 Issuing organization: Isidor Sustainability Research Institute (이시도르 지속가능연구소) Site: HD Hyundai Oilbank Daesan Refinery (182, Daejuk 1-ro, Daesan-eup, Seosan-si, Chungcheongnam-do, Republic of Korea) Products in scope: TPO co-processing — four (4) ISCC EU certified product groups (NHT blend [LN+HN] / TGO / HCR blend [KERO+LGO+HN-cascade] / RN)

Executive Summary

This report presents the unit greenhouse gas emissions (E) and Carbon Intensity (CI) for the four (4) ISCC EU certified product groups produced by co-processing the biogenic fraction of Tire Pyrolysis Oil (TPO; End-of-Life Tires origin, biogenic fraction = 51%) through HD Hyundai Oilbank's Daesan refinery. The calculation applies the general formula in RED II Annex V Part C and the special methodology for co-processing in ISCC 203-01 v2.0 §3.10.

This calculation classifies, at each process, the output streams into Primary product (the ¹⁴C / mass-balance-identified ISCC-certified bio yield) and Co-product (bio mass allocated to the externally sold non-certified outputs of the same process via mass-balance proportional attribution), and computes the Allocation Factor (AF) by energy content per RED II Annex V Part C Point 17. The certified total is 1,078.62 ton_dry (81.9% recovery of DCU bio out 1,317.81 ton). All 16 scenarios pass the RED II 50% saving threshold (lowest saving 75.17% for Indian RN, margin +25.17%p). The v3 calculation also enforces cascade consistency by injecting the upstream process's per-product unit emissions directly into the received e_p·e_td inputs of the downstream process (DCU per-Naphtha → NHT, DCU per-CLGO → GHT, DCU per-CHGO → HCR, HCR per-HN → PLT).

Summary

CI matrix — 4 product groups × 4 origins (g CO₂eq/MJ)

Limitations of this calculation — transparency declaration

This report explicitly declares the following four limitations (see §5.4, §4.3, §5.5, §9.3 for details).

1. Δ = 0 applied (negative-Δ correction) — Following the procedure in ISCC 203-01 §3.10, applying June~December 2025 operating data as Scenario A (Counterfactual) yielded Δ_input(i) < 0 (negative) across every process input item. Because §3.10 states "Any increase in processing inputs ... shall be attributed entirely to the biomass-based fraction," attributing only positive Δ (incremental) to the bio fraction is mandated, and crediting negative Δ to the bio fraction is not justified. Therefore Δ_input(i) = 0 is applied. As a result, Step 1 (incremental attribution) is nullified and only Step 2 (proportional bio-share allocation) is operative.
2. Five-process separate calculation → cascade-integrated presentation — DCU/NHT/GHT/HCR/PLT are calculated in separate worksheets; this report integrates the results into a single cascade flow.
3. Data vintage is 2025 H1 (2026 Q1 not yet available) — The most recent quarter's (2026 Q1) operating and ¹⁴C data are not yet available, so January~May 2025 (151 days) data are used. This is approaching the 12-month update guideline of ISCC EU 205 v4.2 §4.3 for actual values; recalculation is recommended once the next data set is available.
4. Mass-balance proportional allocation of Co-product bio mass — For each process output, the Primary product carries the bio yield identified directly by ¹⁴C or mass balance. The Co-product is the residual bio mass (= bio_input − Primary sum) attributed to the externally sold carbon-bearing outputs of the same process (LPG · Coke · Lean Oil · W/NAPH · LN · Hydrowax, etc.) by Normalize-yield proportional allocation. Waste/residue (H₂S, H₂), self-consumed fuel (Fuel Gas), process recycle (SLOP, Wash Naphtha), and the fossil portions of the same cascade primary streams (LN · HN of NHT, TGO of GHT, HN · KERO · LGO of HCR, RN of PLT) are excluded from the allocation base. The Co-product allocation values are mass-balance estimates rather than direct ¹⁴C measurements; refinement is recommended at the next update (see §9.3.2 Recommendation 5).

1. Introduction (Goal & Scope)

1.1 Reporting purpose and scope

This report calculates the unit greenhouse gas emissions (E) and Carbon Intensity (CI) of four (4) ISCC EU certified co-processed oil product groups produced by co-processing the biogenic fraction of TPO (Tire Pyrolysis Oil from End-of-Life Tires) at HD Hyundai Oilbank Daesan refinery.

The processes in scope form a 5-unit cascade: DCU (Delayed Coker Unit, the TPO entry point) → NHT / GHT / HCR / PLT. The feedstock (TPO) is imported from four (4) origin countries: India / Indonesia / China / Thailand. Because ISCC EU 203 §4.4.3 and ISCC EU 205 §4.3.7 explicitly prohibit aggregating GHG values across batches of different country of origin, this report performs a separate GHG calculation for each of the four origins, resulting in 4 (origins) × 4 (ISCC product groups) = 16 scenarios.

The calculation results serve as evidence for the conformity assessment against ISCC EU certification requirements (ISCC EU 205 v4.2, ISCC 203-01 v2.0, EC IR 2022/996).

1.2 Conformance Statement

This calculation is performed in accordance with the following standards. Each row's right column states how the standard is applied in this calculation.

1.3 Applied scope

1.4 Report structure

This report consists of 10 main sections plus 6 appendices.

2. System Boundaries

2.1 System boundary diagram

The system boundary applied in this report is Cradle-to-Gate (Well-to-Refinery-Gate), covering from end-of-life tire generation to ISCC-certified product dispatch from the Daesan refinery. The combustion stage (e_u) is set to 0 because the feedstock is waste-origin per RED II Annex V Part C §18 and is shown for information only.

2.2 Stages included / excluded

2.3 Temporal and spatial boundaries

• Temporal: 2025-01-01 ~ 2025-05-31 (151 days, 5-month cumulative)
• Spatial: Ports in 4 origin countries → Korea (Daesan refinery) → Korean domestic dispatch terminals

2.4 Functional Unit

The functional unit of this report is 1 MJ_biofuel (Carbon Intensity, g CO₂eq/MJ). RED II Annex V Part C mandates the g CO₂eq/MJ unit for transport-fuel GHG reporting. The ancillary unit kg CO₂eq/ton_dry is used at the §3-§4 stage as supporting figures.

2.5 Cut-off rules

In accordance with ISO 14067 §6.4.5, the following cut-off rules are applied:

• Mass basis: streams below 1% of total production mass are excluded (provided the cumulative excluded mass remains under 5%)
• Energy basis: streams below 1% of total LHV are excluded
• GHG-impact basis: streams whose estimated GHG contribution is below 1% are excluded

Result of application: No stream was excluded by the cut-off rule in this calculation. All inputs and outputs of the 5 process units were tracked.

3. Process Description

3.1 Process flow — 5-unit cascade

The co-processing system at this site begins at the DCU (Delayed Coker Unit, the TPO entry point). Three intermediate streams from the DCU (Naphtha, CLGO, CHGO) feed the NHT, GHT, and HCR respectively, and the HN (Heavy Naphtha) from HCR is further fed to the PLT (Platformer/Reformer) where it is converted to RN (Reformate Naphtha). This is a cascade structure with both serial and parallel branches.

Cascade summary (151-day cumulative, bio basis, ton_dry) — Primary product and Co-product allocation reflected:

3.2 Per-process detail — bio basis (151-day cumulative)

3.2.1 DCU — Delayed Coker Unit

Role: The bio-feedstock entry point where TPO is co-fed with fossil streams (VR/HCR feed). Operating at high temperature (~480~520 °C) and low pressure, it thermally cracks heavy streams (residues) into lighter cuts.

3.2.2 NHT — Naphtha Hydrotreater

Role: Removes sulfur, nitrogen, and olefin impurities from the DCU-derived Naphtha and separates it into LN (Light Naphtha) and HN (Heavy Naphtha). Catalytic hydrotreatment is used, with H₂ as a reagent.

3.2.3 GHT — Gasoline Hydrotreater

Role: Hydrotreats the DCU-derived CLGO (Cracked Light Gas Oil) to produce TGO (Treated Gas Oil), reducing sulfur content in the diesel range.

3.2.4 HCR — Hydrocracker

Role: Cracks and hydrotreats the DCU-derived CHGO (Cracked Heavy Gas Oil) under high-pressure H₂ atmosphere, simultaneously, producing the lighter cuts KERO (Kerosene), LGO (Light Gas Oil), and HN (Heavy Naphtha). H₂ consumption is the largest among the 5 processes (cumulative ~19,840 MMSCF over 151 days).

Note: HCR's high own e_p is driven by (i) ~45.17 GWh electricity, (ii) ~21,000 ton H₂ consumption over 151 days, and (iii) the lowest Primary bio recovery among 5 processes (48.2%). In addition to BIO-KERO · BIO-LGO · BIO-HN, 60.83 ton of bio is allocated as Co-product across the LPG · LN · Hydrowax and other externally sold streams of the process. Own e_p is calculated against the Primary yield of 56.53 ton (out of 117.35 ton BIO-CHGO fed to HCR). The saving margin for HCR-cascade products (BIO-KERO · BIO-LGO · BIO-HN, PLT BIO-RN) is reported in §7.

3.2.5 PLT — Platformer (Reformer)

Role: Reforms the HCR-derived HN (Heavy Naphtha) over a Pt catalyst into RN (Reformate Naphtha). This is the final stage of the cascade and has the smallest own e_p among the 5 processes.

3.3 ¹⁴C measurement results (ASTM D6866)

3.4 Basis for waiving ¹⁴C measurement at downstream processes

Among the five processes at this site, the only point where a ¹⁴C sample was directly drawn and analysed is the TPO baseline immediately upstream of DCU input. No re-measurement of ¹⁴C was performed for the intermediate streams that branch out from the DCU outlet (BIO-Naphtha → NHT, BIO-CLGO → GHT, BIO-CHGO → HCR) nor for BIO-HN that cascades from HCR to PLT. The justification for this waiver is as follows.

Justification 1 — ISCC EU PLUS Procedure CoC v6.0 §02.07.013 — When a co-processing site has carried out ¹⁴C measurement at the baseline entry point (here, immediately upstream of DCU input), there is no obligation to re-measure ¹⁴C at the downstream cascade processes.

Justification 2 — ISCC 203-01 §3.5.1 Method B (¹⁴C-calibrated yield) — The DCU's ¹⁴C-cal yield factor (C-Naphtha 6.20% / CLGO 82.83% / CHGO 8.74% / Loss 2.23%), combined with the baseline ¹⁴C measurement, quantitatively determines the bio fraction in each branch leaving DCU. The downstream NHT/GHT/HCR/PLT are simple refining/separation/reforming processes with no path that alters the ¹⁴C ratio (no introduction of additional fossil carbon and no addition of biogenic carbon). Therefore the yield ratios derived from the baseline ¹⁴C measurement apply uniformly across the downstream cascade.

Justification 3 — Robust calculation principle — ISCC 203-01 recognises a single baseline measurement combined with ¹⁴C-cal yield as a robust calculation, and this calculation conforms to that procedure. For the next update, ¹⁴C re-sampling for each of the four origins is recommended (see §9.3.2 Recommendation 3).

3.5 Meaning of cascade — Own vs Received

The 5 processes at this site are not a single-reactor configuration but a cascade (mixed serial/parallel) structure, and the GHG of each process comprises the following two parts:

1. Own e_p (Own) — Emissions arising in that process from electricity, heat, H₂, and wastewater treatment (after applying the co-processing ratio and converting per unit yield)
2. Received e_p (Received) — Cumulative GHG from the upstream process (or supplier), aggregated after FF correction

The site-specific implementation of this cascade calculation methodology is detailed in §5.

4. Data Quality Assessment

4.1 Primary vs Default data classification

Default priority order:

1. EC IR 2022/996 Annex II
2. RED II Annex V default
3. ISCC EU 205 default
4. IPCC 2006 GL Tier 1 EF (Vol.2 Energy / Vol.5 Wastewater)

4.2 Data source list

Meaning of the operating-data workbook: "TPO biogenic operating data (monthly aggregation).xlsx" is operational data organised monthly (from 2023-01) for each of the five processes (DCU·#1NHT·#1GHT·HCR·#1PLT), covering both inputs (auxiliary materials, water, energy, utilities) and outputs (products, by-products, generated energy). The §6.1 process-input matrix in this report is built by extracting the 2025-01~05 columns (the 151-day reporting period) from this workbook, and serves as the primary data source for own e_p calculation. Because the workbook mixes per-hour averages (kWh/h, T/H, etc.) and monthly aggregates (kg, Nm³, etc.), this calculation prefers the explicit "monthly aggregation" rows, while per-hour-average rows are converted to cumulative values using the reporting period (151 days × 24 h = 3,624 h).

4.3 Data vintage and representativeness — declared limitation

The data window of this calculation is 2025-01-01 ~ 2025-05-31 (151 days). As of the report issue date (2026-05-15), operating and ¹⁴C data for the most recent quarter (2026 Q1) are not yet available.

Limitation assessment

• From an ISCC EU 205 v4.2 §4.3 perspective: Actual values are recommended to be drawn from data within the past 12 months. From the data end (2025-05-31) to the report issue date (2026-05-15), ~11.5 months have elapsed — close to the 12-month threshold.
• Representativeness assumption: The calculation assumes the 151-day window is representative of the site's annual average operations. GHG variations from seasonality (e.g., gas demand in winter), utilization fluctuations, and TPO supply variability are not reflected.
• Update obligation: This report shall be recalculated once 2026 Q1 data become available. The update scope shall include ¹⁴C measurement, per-process own e_p, and transport e_td variations.

§9.3 details the follow-up recommendations.

4.4 Data quality scoring (Pedigree Matrix)

Scoring 1~5 (1 = highest quality) using the Pedigree Matrix recommended in ISO 14040/44 annex.

Interpretation: Site-operated data (TPO input, own e_p) score 1~2 (high quality). The received e_p from the external TPO supplier is heavily dependent on default values, scoring 3 (moderate quality) — flagged as a key sensitivity variable in §8.

4.5 Assumptions and limitations

• (Assumption 1) TPO biogenic fraction is uniformly applied as 51% across all 4 origins (the ¹⁴C measurement was performed on a representative Indian sample).
• (Assumption 2) Own e_p of the 5 processes is invariant across origins (a single operational value).
• (Assumption 3) Δ_input(i) = 0 applied — Applying June~December 2025 operating data as Scenario A produced negative Δ for every process input. Per the §3.10 rule (only positive Δ attributable to bio), it is appropriate not to credit the bio fraction with a negative Δ; this is conservatively set to 0 (see §5.4 for details).
• (Limitation 1) A 151-day window does not fully represent the site's annual average.
• (Limitation 2) Some e_td routing assumptions use defaults.

5. Methodology

5.1 RED II Annex V Part C §1 — General formula

E = e_ec + e_l + e_p + e_td + e_u − e_sca − e_ccs − e_ccr   [g CO₂eq/MJ]

5.2 Waste/residue treatment — items set to 0

TPO is derived from End-of-Life Tires; per RED II Annex V Part C §18 and ISCC EU 202-5 v4.2, it is classified as Waste & Residues. Accordingly:

• e_ec = 0 (no feedstock-extraction emissions)
• e_l = 0 (no LUC)
• e_sca = 0 (not applicable)
• e_u = 0 (biogenic CO₂; shown for information only)
• e_ccs = e_ccr = 0 (no such process at this site)

Therefore, the only terms with non-zero contribution to this calculation are e_p (process emissions), e_td,up (upstream transport), and e_td,down (downstream transport) — three terms.

Origin-country waste classification — all 4 countries classify End-of-Life Tires as waste (or residue) under their respective laws:

5.3 ISCC 203-01 v2.0 §3.10 — Two-Scenario Benchmark Method

5.3.1 Difference between conventional GHG calculation and co-processing

Conventional (bio-only) biofuel sites use 100% bio feedstock (e.g., UCO, tallow, PFAD), so they directly compute e_p by dividing process activity (electricity, heat, H₂, wastewater) by the output yield.

Co-processing refineries (such as this site, where fossil and TPO are co-fed to the same reactor) have process inputs driven primarily by fossil-feed processing, while the bio fraction is typically very small (0.1~5%). A naive "bio fraction × total process emissions" approach introduces two errors:

• (a) Underestimation — Additional H₂/electricity consumption (e.g., for deoxygenation) caused by bio feedstock is masked within the fossil emissions
• (b) Overestimation — Processing burden that fossil alone would always have generated is partially attributed to bio, inflating the bio share

To resolve this, ISCC EU 203-01 §3.10 introduces the Two-Scenario Benchmark Comparison.

5.3.2 Comparison of two scenarios

Key constraint: The total feedstock energy content (LHV × tonnage) of the two scenarios must remain identical.

Original text:

"To assess the GHG emissions of a co-processing plant processing biomass- and fossil-based feedstocks simultaneously, it is required to determine the processing inputs associated with just the biogenic feedstock. This should be performed by comparing two scenarios: In the first scenario, the refinery is processing only fossil-based feedstocks and in the second scenario the refinery is processing both biomass- and fossil-based feedstocks together, provided that the total energetic content of the feedstock in both scenarios remain the same. Any increase in processing inputs, after considering the two scenarios, shall be attributed entirely to the biomass-based fraction of the feedstock." — ISCC 203-01 v2.0 §3.10

5.4 3-step calculation procedure (§3.10 + ISCC EU 205 §10) — Δ = 0 applied in this calculation

Step 1 — Determination of excess inputs

Standard formula: Δ_input(i) = Input(i)_{co-processing} − Input(i)_fossil-only

This excess Δ is attributed entirely to the bio fraction.

Application in this calculation — Δ_input(i) = 0 (negative Δ resulting from counterfactual data)

A Two-Scenario Comparison was attempted in line with ISCC 203-01 §3.10:

• Scenario B (Actual): January~May 2025 (151 days, co-processing operations)
• Scenario A (Counterfactual): June~December 2025 operating data applied as the reference

Comparing the process inputs (H₂, electricity, steam, fuel gas, wastewater treatment) of the two scenarios, Δ_input(i) = Input(i)_{co-processing} − Input(i)_fossil-only resulted in negative values for all items. This is interpreted as a consequence of Scenario A (June~Dec 2025) operating conditions (feed quality, utilization, scheduled-maintenance schedule, etc.) not being identical to Scenario B (Jan~May 2025).

ISCC 203-01 §3.10 explicitly states "Any increase in processing inputs, after considering the two scenarios, shall be attributed entirely to the biomass-based fraction of the feedstock," mandating that only positive Δ be attributed to the bio fraction. A negative Δ cannot be interpreted as a credit indicating "bio reduces fossil's processing burden," and crediting in such a way exceeds the explicit scope of §3.10.

Therefore, in conformity with conservative application, Δ_input(i) = 0 is applied to every process input item i. As a result, Step 1 (incremental attribution) is nullified, and only Step 2 (proportional bio-share allocation) is operative — meaning the §3.10 methodology is partially applied.

Step 2 — Proportional bio-share allocation

The remaining process inputs (i.e., the fossil-only inputs of the Counterfactual scenario) excluding Δ are allocated proportionally based on bio/fossil energy content.

Bio-share = (M_bio · LHV_bio) / (M_bio · LHV_bio + M_fossil · LHV_fossil)

This calculation (DCU level):

• M_bio = 1,348.84 t × 40.0 MJ/kg = 53,953,600 MJ
• M_fossil = 905,931 t × 42.0 MJ/kg = 38,049,102,000 MJ (assumed average fossil LHV)
• Bio-share ≈ 0.00142 (0.142%)

Step 3 — Attribution to bio fraction

The result of Step 2's proportional allocation is attributed to the bio output products (yield), producing own e_p.

Own e_p of the 5 processes (151-day cumulative, kg CO₂eq/ton_dry, (151-day cumulative)):

Interpretation: HCR's own e_p is the largest because the certified bio yield (56.53 ton) is small relative to the BIO-CHGO feed (117.35 ton), making the per-unit denominator small. The "Proportion of Coprocessing" (bio_in / total_input) in each e_p_ worksheet is set according to the mass balance of that process.

Impact assessment of Δ = 0 application

Conservativeness of the basis:

• If a measured negative Δ were applied at face value, a credit "co-processing reduces fossil's processing burden" would be attributed to bio, further reducing the GHG of bio products
• However, §3.10 mandates attribution of only positive Δ — there is no standards-based justification to credit a negative Δ
• Setting Δ = 0 is a conservative, defensive treatment that blocks unwarranted credit potentially arising from negative Δ

Effect on calculation results:

• Setting Δ = 0 eliminates the difference between Scenarios A and B; the remaining inputs are allocated by bio-share → the GHG of bio products in this calculation is at the 15.15 ~ 23.34 g CO₂eq/MJ level
• Had the negative Δ been applied as is, bio-product CI would have been even lower than the values in this calculation (i.e., this calculation is conservative)
• Because the bio-share is only 0.142% in this calculation, the absolute-value impact of the Δ treatment is limited
• All 16 scenarios clear the 50% threshold by at least +25.17%p margin (see §8 sensitivity)

5.5 Allocation method — ISCC EU 205 §4.3.8 (RED II Annex V Part C Point 17)

GHG emissions from each process are allocated to outputs by energy content (mass × LHV). Each process's output streams are classified into two categories:

AF = E(Primary) / [E(Primary) + E(Co-product)]

• E(Primary) = Σ (Primary bio_mass × LHV) (MJ)
• E(Co-product) = Σ (allocated bio_mass per target stream × LHV) (MJ)
• LHV: IPCC 2006 GL Vol.2 Ch.1 Table 1.2 defaults + ISCC EU 205 §5.4 defaults (hyperlinks and comments in the master calculation worksheet's LHV columns)

Per-process AF (data: master calculation worksheet first tab bio(Jan-May 2025)수율 변경, 151-day cumulative)

<Table 5-1> Per-process Primary · Co-product and AF

LHV values (GJ/ton, source): LPG 46.0 (IPCC) / Naphtha · LN 44.5 (IPCC) / HN 43.5 (ISCC) / KERO 43.8 (IPCC) / CLGO · CHGO · LGO · TGO 43.0 (IPCC) / W/NAPH 44.5 (IPCC) / Hydrowax 43.5 (Industry) / Coke 32.5 (IPCC) / RN 44.0 (IPCC) / Lean Oil 43.0 (Industry) / H₂S 0 (no carbon).

Co-product bio mass allocation procedure (3 steps)

Step 1 — Co-product bio mass total: bio_input minus Primary sum, giving the residual bio mass to be allocated to externally sold streams.

Step 2 — Identify allocation-target streams: only externally sold carbon-bearing streams that are not part of the cascade primary product. The following streams are excluded from the allocation base.

Step 3 — Normalize-yield proportional allocation: bio_stream = Co-product bio total × (Normalize yield_stream / Σ allocation-target Normalize yield).

<Table 5-2> Co-product bio mass allocation result (documented in the master calculation worksheet)

Interpretation: HCR has the lowest AF because, of the 117.35 ton BIO-CHGO fed into HCR, only about half (56.53 ton) is recovered as Primary product (BIO-HN + BIO-KERO + BIO-LGO); the remaining 60.82 ton is allocated mostly to Hydrowax (94.6% allocation share) as Co-product. The Co-product bio energy is comparable to the Primary energy, giving AF ≈ 0.48. NHT and GHT have Primary bio recovery around 85%, while DCU and PLT have small allocation amounts, giving AFs above 0.9.

5.6 Feedstock Factor (FF) — ISCC EU 205 §4.3.7

FF = M_f,total / M_o,total

• M_f,total: total feedstock input (ton_dry)
• M_o,total: total output yield (ton_dry)

This calculation (151-day bio basis, Co-product allocation reflected):

Interpretation: Within each downstream process the bio fraction flows between the Primary product (BIO-LN · BIO-HN · BIO-TGO · BIO-KERO · BIO-LGO · BIO-RN) and the Co-product allocation to externally sold streams of the same process (LPG · Lean Oil · W/NAPH · Hydrowax, etc.). The Co-product allocation amounts are about 10.57 ton (NHT), 172.43 ton (GHT), 60.83 ton (HCR), and 0.35 ton (PLT). The Primary product total is 1,078.64 ton_dry (DCU bio out 1,317.81 ton, 81.9% recovery).

5.7 Transport emissions (e_td) calculation

Mandatory origin-segregated calculation (ISCC EU 203 §4.4.3 + ISCC EU 205 §4.3.7)

Performing separate e_td calculations for each of the 4 origins (India / Indonesia / China / Thailand) is mandatory under ISCC rules. ISCC EU 205 §4.3.7 only allows aggregation of incoming GHG values where "both the product identity and the GHG value are identical," and ISCC EU 203 §4.4.3 "explicitly prohibits aggregation of batches with different country of origin" (see 203 Figure 10). That is, neither weighted averaging nor even the "highest value" simplification option is permitted, and origin-segregated calculation plus origin-segregated Sustainability Declaration forwarding is a hard requirement. The 16-scenario segregated structure of this report meets this requirement.

Transport emissions are calculated separately for each origin and segment. For each origin, the e_td.Opt1.〈origin〉 sheet computes the following three segments:

Per-origin own e_td,up (151 days, kg CO₂eq/ton_dry, at DCU):

6. Inventory Analysis (LCI)

6.1 Process input matrix (151-day cumulative, bio basis)

This matrix is built by extracting the 2025-01~05 columns from the five process sheets (DCU·#1NHT·#1GHT·HCR·#1PLT) of "TPO biogenic operating data (monthly aggregation).xlsx". Each sheet organises inputs (auxiliary materials, water, energy, utilities) and outputs (products, by-products, generated energy) on a monthly basis; this calculation uses the cumulative values for the reporting period (151 days) as the primary data source for own e_p.

Note: Because the operating-data workbook mixes per-hour-average units (e.g., kWh/h, T/H) and monthly-aggregate units (e.g., kg, Nm³), this matrix prefers the explicit "monthly aggregation" rows where available, while per-hour-average rows are converted to cumulative values using the reporting period (151 days × 24 h = 3,624 h). The detailed raw values and conversion procedure are available in "TPO biogenic operating data (monthly aggregation).xlsx" and the GHG calculation worksheets.

6.2 Process outputs (bio basis, 151 days)

See §3.2. Under the mass balance model, four (4) certified product groups + cascade intermediate:

• NHT blend [LN 34.40 + HN 38.66] = 73.06 ton_dry
• TGO (GHT) = 944.41 ton_dry
• HCR blend [KERO 16.30 + LGO 35.23 + HN 4.99] = 56.52 ton_dry
• RN (PLT) = 4.64 ton_dry
• Certified total = 1,078.64 ton_dry (81.9% recovery of DCU bio out 1,317.81 ton)
• HCR-HN (cascade intermediate) 4.99 ton_dry → PLT input

6.3 Feedstock input (per origin × month)

TPO input is a single mass (1,348.84 t) split across 4 origins. The per-origin allocation ratio is in the separately attached file (TPO Flow xlsx).

6.4 ISCC EU mapping

This calculation aggregates LN·HN of NHT and KERO·LGO·HN of HCR as a blended single certified product group each, without separate reporting. At CB certificate issuance, the unit CI (g CO₂eq/MJ) of each blend is used as the certified value; if a dispatch batch is separated into a single LN or HN stream, the same unit CI applies.

LN within the NHT blend and RN (PLT) share part of the ISCC EU category name (Petrol/Naphtha), but they are produced through different processes and therefore belong to separate Coprocessing certification scopes. An ISCC EU coprocessing scope is defined as "the starting process (DCU) + one downstream process," so NHT blend (DCU+NHT) and RN (DCU+PLT) are calculated and certified as separate scopes; this report likewise treats them as distinct scenarios within the 16 scenarios.

7. Results

7.1 Stage-wise GHG breakdown — range across 16 scenarios

The non-zero contributing terms in this calculation are e_p, e_td,up, and e_td,down; other terms are 0 due to waste classification, biogenic-CO₂ treatment, or absence of the process at this site. Differences across the 4 origins and 4 product groups arise mainly from e_p (process/product) and e_td,up (origin-specific transport distance).

7.2 Per-product-group unit GHG (g CO₂eq/MJ)

Reproducing the matrix from the Executive Summary:

7.3 Average per origin

Average CI per origin is energy-weighted by the certified bio energies (NHT 3,212 / GHT 40,610 / HCR 2,446 / PLT 204 GJ; sum ≈ 46,472 GJ).

Interpretation: TGO (GHT) accounts for 87.4% of the certified-bio energy basis, so the weighted average lies close to TGO's CI (15.15~16.42 g/MJ). Across the four product groups, the single PLT-RN CI of 22.16~23.34 g/MJ is highest, but its share of certified energy is only 0.4%, so it has limited influence on the weighted average. For threshold evaluation, RN (PLT) is the decisive scenario.

7.4 Saving vs fossil comparator — RED II Article 29(10)(a) 50% threshold

Fossil comparator: 94.00 g CO₂eq/MJ (EC IR 2022/996, RED II Annex V Part C §19)

All 16 scenarios clear the 50% threshold. The lowest saving is 75.17% for Indian RN, leaving a +25.17%p margin above the 50% threshold. The highest saving is 83.88% for Chinese TGO.

8. Sensitivity / Uncertainty Analysis

8.1 Key variable identification

The following 8 key variables are perturbed by ±10% to assess their impact on the final CI:

1. Per-origin TPO e_ec (received e_p) — current default 83.28 kg CO₂eq/ton_dry
2. Korea grid electricity EF — 0.4781 kg CO₂eq/kWh (EG-TIPS)
3. DCU + HCR own process energy consumption (electricity, H₂)
4. LNG / fuel gas consumption and EF — natural gas / fuel gas inputs to site boilers and heaters (HCR + DCU + NHT total being the largest)
5. Steam consumption and own-boiler EF — HPS/MPS/LPS totals across 5 processes (HCR + DCU being the largest)
6. Wastewater generation and treatment GHG factor — sensitivity to IPCC 2006 GL Vol.5 Ch.6 Tier 1 EF
7. Feedstock Factor (FF) — DCU 1.02
8. Δ_input(i) assumption — currently 0; impact if Δ is corrected to a positive value

8.2 Re-evaluation of 50% threshold compliance under altered assumptions

Under the most conservative scenario (all sensitivity variables +10%, Δ corrected to the maximum estimable positive value), the lowest-saving product (Indian RN) is estimated at about 70~73% saving — well above the 50% threshold (+20%p safety margin). The other three product groups (NHT blend, TGO, HCR blend) maintain ≥75% PASS under all conservative scenarios.

8.3 Uncertainty assessment method — IPCC 2006 GL Vol.1 Ch.3

This calculation applies IPCC 2006 GL Vol.1 Ch.3 Approach 1 (Error Propagation). Under the variable-independence assumption, the 95% confidence interval ± is computed.

Average CI 95% confidence interval (energy-weighted, Indonesia basis):

• 15.71 g CO₂eq/MJ ± 2.18 g CO₂eq/MJ (±13.9%)

PLT-RN single-scenario confidence interval (China, lowest saving):

• 23.34 g CO₂eq/MJ ± 3.22 g CO₂eq/MJ (±13.8%) → 95% CI of saving = 71.7 ~ 78.6%, comfortably above the 50% threshold

9. Conclusions and Conformance Statement

9.1 Summary of calculation results

This report has calculated the unit GHG emissions and Carbon Intensity (CI) of four (4) ISCC EU certified product groups (NHT blend [LN+HN], TGO, HCR blend [KERO+LGO+HN-cascade], RN) produced from the TPO co-processing operation at HD Hyundai Oilbank's Daesan refinery, separately for the four origins (India, Indonesia, China, Thailand).

• Mass balance model: DCU bio output (1,317.81 ton_dry, BIO-Naphtha / CLGO / CHGO) flows through the NHT/GHT/HCR/PLT cascade to the ISCC-certified bio outputs (NHT 73.06 + TGO 944.41 + HCR 56.53 + PLT 4.64 = 1,078.62 ton_dry; recovery 81.9%).
• Allocation Factor (AF): RED II Annex V Part C Point 17 energy-based allocation. Primary product = directly identified ISCC-certified bio mass; Co-product = sum of bio mass attributed by mass-balance proportional allocation to the externally sold streams of the same process. AF = E(Primary) / [E(Primary) + E(Co-product)]. DCU 0.9824 / NHT 0.8706 / GHT 0.8411 / HCR 0.4801 / PLT 0.9271.
• CI range across 16 scenarios: 15.15 ~ 23.34 g CO₂eq/MJ
• Saving vs fossil comparator (94 g CO₂eq/MJ): 75.17 ~ 83.88%
• All 16 scenarios PASS the RED II Article 29(10)(a) 50% threshold (lowest margin +25.17%p for Indian RN)

9.2 ISCC EU certification scope conformance declaration

This calculation conforms to the following ISCC EU certification requirements:

• ISCC EU 205 v4.2 §10 — Co-processing GHG calculation guide applied
• ISCC 203-01 v2.0 §3.10 — Two-Scenario Benchmark Method applied (Δ=0 limitation declared)
• ISCC EU 202-5 v4.2 — TPO classified as waste/residue (basis for e_ec=e_l=e_sca=0)
• ISCC EU 203 v4.2 — Mass balance traceability
• ISCC EU 201 v4.2 — System basics (certification scope, primary product)
• EC IR 2022/996 — Self-calculation verification procedure and certificate format conformity

9.3 Limitations and follow-up recommendations

9.3.1 Declared limitations (4 items)

1. Δ_input(i) = 0 (negative-Δ correction) — Applying June~December 2025 operating data as Scenario A produced negative Δ for every process input. Since §3.10 mandates that only positive Δ (incremental) be attributed to bio, conservatively declining to credit the bio fraction with a negative Δ (Δ = 0) was deemed appropriate. As a result, Step 1 is nullified and only Step 2 (proportional allocation) is operative. The bio-share is 0.142%, very small, so the absolute-value impact of the Δ treatment is limited.

2. Data vintage — 2025 H1 (151 days) — 2026 Q1 operating and ¹⁴C data are not available. Approaching the 12-month actual-values guideline of ISCC EU 205 §4.3.

3. Single-origin ¹⁴C sample representativeness — The bio fraction of 51% is based on a representative Indian sample (KATRI SBED26-141K~144K). Applied uniformly to all 4 origins as an assumption.

4. AF denominator scope — energy-based proportional allocation — Per RED II Annex V Part C Points 17·18, the denominator includes certified bio + non-certified saleable co-products of the same process. Excluded: waste/residue (H₂S), self-consumed fuel (Fuel Gas), process recycle (SLOP, Wash Naph), and internal-processing streams (H₂, Lean Oil, CLPS Liquid). Because the bio output occupies only 0.005% ~ 0.38% of each cascade-stage's energy, AF_bio is at the same magnitude — a RED II-consistent outcome guaranteeing the same per-MJ GHG burden as fossil co-products. Refinement of AF via confirming LPG external-sale destinations is recommended for the next update (see §9.3.2 Recommendation 5).

9.3.2 Follow-up recommendations

• Recommendation 1 — Recalculate this report once 2026 Q1 data become available. Recommended update window: 2026 H2 (2026-09 ~ 2026-12).
• Recommendation 2 — Refine the counterfactual comparison — In this calculation, June~December 2025 operating data were used as Scenario A, but the difference in operating conditions resulted in negative Δ. For the next update, we recommend (i) tightening the operating-condition consistency between Scenarios A and B (aligning feed quality, utilization, and scheduled-maintenance), and (ii) introducing an LP-model-based fossil-only simulation to derive a theoretical reference value. If Δ can then be derived as a meaningful positive value, formally apply Step 1 (incremental attribution) of §3.10.
• Recommendation 3 — Origin-segregated ¹⁴C measurement — Conduct ¹⁴C analyses on representative TPO samples from each of the 4 origins (India / Indonesia / China / Thailand).
• Recommendation 4 — External review (Critical Review) — For comparative assertions per ISO 14067 §6.7, introduce an external verifier review procedure.
• Recommendation 5 — Co-product destination refinement — Confirm with the operations team the actual external-sales fraction of LPG / Naphtha / HN / KERO / LGO / RN / Hydrowax / Coke entering the AF denominator, and correct the denominator mass accordingly. Exclude any internally consumed portion from the denominator.
• Recommendation 6 — Refinement of own e_p — Own e_p absolute values determine that all 16 scenarios clear the 50% threshold by +49.99%p or more. Prioritise verifying the attribution accuracy of electricity, H₂, steam, fuel gas, and wastewater items at the next update.

9.4 Conformance statement

This calculation has been performed in accordance with RED II (Directive (EU) 2018/2001) Annex V Part C §1, ISCC EU 205 v4.2 §4.3.8, and ISCC 203-01 v2.0 §3.10. Certification scope, definitions, and targets (Article 29 etc.) cross-reference the amendments in RED III (Directive (EU) 2023/2413). The reporting requirements of ISO 14067:2018 §6 are met.

Data collection window: 2025-01-01 ~ 2025-05-31 (151 days). Basis for saving against the fossil comparator: EC IR 2022/996 (94 g CO₂eq/MJ).

Limitations applied to this calculation (Δ=0, data vintage 2025 H1, single-origin ¹⁴C sample) are declared in §9.3 and shall be addressed in the next update.

The four ISCC EU certified product groups have unit CIs of 15.15 ~ 23.34 g CO₂eq/MJ, with all 16 scenarios (4 product groups × 4 origins) passing the RED II 50% threshold by a margin of at least +25.17%p. AF is computed per RED II Annex V Part C Point 17 energy-allocation principle by classifying outputs into Primary product (directly identified ISCC-certified bio) and Co-product (bio mass attributed by mass-balance proportional allocation to the externally sold streams of the same process): DCU 0.9824 / NHT 0.8706 / GHT 0.8411 / HCR 0.4801 / PLT 0.9271.

Prepared by: Yoon Ji Yong (Isidor Sustainability Research Institute) / Reviewed by: Yu Byeong Deok (Isidor Sustainability Research Institute) / Verified by:

10. Appendices

Appendix A. Calculation details (per-process and per-origin worksheets)

The detailed worksheets (separately attached, 5 series per origin) are provided under the following filenames:

In each sheet, the §1 Received Unit Emissions / §2 FF Adjusted / §3 non-allocated / §4 allocated / §5 per-product CI are the direct sources for the result matrices in §7 of this report.

Appendix B. ¹⁴C analysis report (KATRI SBED26-141K~144K)

A copy of the test report is attached separately. Key information:

• Test method: ASTM D6866 (AMS)
• Test laboratory: KATRI (Korea Apparel Testing & Research Institute)
• Sample No.: SBED26-141K, 142K, 143K, 144K
• pMC: 50.73%
• Biogenic fraction: 51.00%

Appendix C. Data source list

Appendix D. Methodology derivation details

See §5 in the main text: RED II Annex V Part C §1 formula, ISCC 203-01 §3.10 Two-Scenario Benchmark, ISCC EU 205 §4.3.7 FF, §4.3.8 energy-based allocation.

Appendix E. Definitions and glossary

Appendix F. External review / Critical Review

This report shall be verified via the ISCC CB audit procedure. A separate Critical Review for comparative assertions per ISO 14067 §6.7 is to be considered at the next update per Recommendation 4 in §9.3.2.