Summary
While robust sustainability rules already exist for bioenergy and biofuels under Directive (EU) 2018/2001 (RED III), no comparable, harmonised framework applies to biomass used in chemicals,
materials, and other non-energy applications. This potentially creates regulatory fragmentation, uncertainty for operators, and barriers to investment in Europe’s emerging bioeconomy value chains. This paper proposes an EU-wide sustainability framework for biomass used in products tied to market pull measures, such as a binding end-product-level biomass-derived content mandate.
Key takeaways
The framework builds on 4 core pillars:
- Alignment with RED III sustainability criteria, using Article 29(2–7) as a basis and adapting where needed to reflect the specificities of non-energy uses.
- Recognition of existing applicable and credible voluntary certification systems already applied widely in agriculture and forestry, provided they uphold RED III principles and are verified by third-party,
accredited, independent auditors against these principles. - Robust climate safeguards, via a lifecycle-based evaluation of greenhouse gas (GHG) emissions. An environmental impact evaluation of products is needed to enable fair comparison with fossil
equivalents. Such a comparison should be executed using an internationally recognised method (e.g., ISO 14067:2018), or—where relevant—a robust regional methodology (e.g., the EU’s PEF). Regardless, the methodology selected should follow the so-called “-1/+1 approach” and should ensure that there is no burden shifting, double counting, or over- or under-estimation of GHGs, thus
enabling a transparent evaluation of the climate performance. - Wide feedstock eligibility: all feedstock types should remain eligible as long as they meet the biomass sourcing sustainability requirements of RED III Article 29(2-7), or comparable criteria in established certification schemes as set out in point 2.