AACS - Complaints procedure

As the AMA is both the operator of the AACS and the certification authority and regulatory body, it will process and investigate any complaints relating to the AACS in order to maintain its reliability and integrity. To submit a complaint/appeal, please use the following forms, which must meet the criteria listed below.

The legal basis for complaint management under the AACS system is Directive (EU) 2018/2001 and its implementing regulation (EU) 2022/996 of 14 June 2022 on "Rules for the verification of sustainability and greenhouse gas emission saving criteria and low indirect risk land use change criteria", in particular Article 5. 

Formal criteria for the validity of a complaint/a appeal

  • The AMA is the recipient of complaints/appeals within the scope of its activities for the AACS system.
  • Complaints/Appeals may be lodged by economic operators, certification bodies, other national authorities or bodies of the European Commission, non-governmental organisations (NGOs) or other third parties.
  • Complaints/Appeals must be submitted in writing, by fax or online.
  • The complaint/The appeal must be described in the accompanying documents in such a way that an independent party can form an opinion of the situation on the basis of the documents.

Content criteria for complaint assessment/appeals

  • Content criteria for assessing complaints Reason for the complaint/appeal (against whom is the complaint/appeal directed, type and quantity of sustainable goods, description of the business case, etc.)
  • Possible magnitude
  • Possible causes
  • Possible effects

If the complaint/appeal is incomplete or unclear with regard to the above criteria, the complainant/appellant should be contacted to obtain the missing information from their perspective. If the complaint/appeal was submitted anonymously and cannot be assigned to a specific case or used to obtain input based on the information available, the complaint/appeal will not be processed. They will be filed in the AMA Matrix documentation. If the content of a complaint/appeal can be assigned to a specific case, the complaint/appeal will be processed in any case, even if not all formal or content-related characteristics of a complaint/appeal are present.

Complaint/appeal processing

  • The complaint/appeal must be analysed and documented by the department responsible for the AACS system.
  • The complaint/appeal must be processed within a specified period of 10 days.
  • A decision must be made as to whether the complaint/appeal is sufficiently relevant or whether there is reasonable suspicion to investigate it further.
  • If the complaint is relevant or there is reasonable suspicion, the sender, if known by name, shall be informed immediately of the receipt of the complaint/appeal and the further procedure.
  • If a complaint/appeal is directed against a participant in the AACS, that participant shall be requested to examine the reason for the complaint/appeal.
  • The participant concerned shall be given a reasonable period of time to submit a written statement.
  • If they do not raise any objections to the complaint/appeal, they will be asked to remedy the reason for the complaint/appeal and its causes. In the event of a complaint or if necessary, an extraordinary on-site inspection may be ordered to further clarify the facts. After the on-site inspection has been carried out, the result must be reviewed.
  • If the result of the on-site inspection is unsatisfactory and violations are found, sanctions shall be imposed.
  • If the cause of the complaint could not be eliminated, further measures shall be taken until it is finally eliminated.

At the request of the European Commission, the AMA shall submit all documents relating to a complaint/appeal and its handling by the AACS.