Background

The EU has committed to reaching climate neutrality by 2050 in order to secure a liveable future on our continent and our planet. The first and most urgent priority is the reduction of EU greenhouse gas (GHG) emissions, but at the same time the EU needs to compensate for residual emissions that cannot be eliminated – by removing carbon from the atmosphere to decrease the overall carbon that is present. These carbon dioxide removals (CDR) are negative emissions because they reduce the amount of CO2 in the atmosphere. According to the Intergovernmental Panel on Climate Change (IPCC), carbon removal is necessary in order to limit global warming to 1.5°C.

To promote sustainable solutions and innovative carbon capture and storage technologies, the European Commission has presented a proposal for the first EU-wide voluntary framework for a reliable certification of high-quality carbon removals (Carbon Removal Certification Framework, CRCF). The proposal sets out criteria to define high-quality carbon removals and lays out the process for monitoring, reporting and verifying the authenticity of these removals. This certification framework aims to boost innovative carbon removal technologies and sustainable carbon farming solutions, while also fighting greenwashing.

The role of bioenergy

There are many different CDR technologies, including several that utilise biomass. The two main technologies are (1) bioenergy with carbon capture and storage and (2) biochar carbon removal. Bioenergy with Carbon Capture and Storage (BECCS) involves any energy pathway where CO2 is captured from a biogenic source and permanently stored. BECCS is a more cost-effective technology for reducing carbon dioxide than many alternatives. But despite BECCS being effective in terms of the amount of carbon dioxide that is reduced, the costs associated with implementation of this technology are high. Updated regulations and new economic instruments are therefore necessary for enabling the creation of large carbon sinks. Biochar Carbon Removal (BCR) involves a chemical process called pyrolysis. Pyrolysis takes place at a lower temperature than combustion – and involves the vaporisation of compounds and elements other than carbon in the biogenic material – leaving only solid, pure carbon behind. This material, called biochar, can then be used to enhance soil in agriculture or to act as an additive in concrete, among other applications.

Our position

Bioenergy Europe welcomes the European Commission’s CRCF proposal to develop high-quality carbon removals in Europe and enable climate neutrality. The proposal outlines the start of a process, and we support a sound and harmonised governance framework that is very much needed for this essential sector. There is clear need for further details from the Expert Group and secondary legislation, considering that the QU.A.L.ITY criteria generally focus on high-quality removals – if they are based on robust quantification – to ensure that net removal is being delivered. We believe that there is too much fragmentation in voluntary space; and having a scheme developed at the EU level will provide greater certainty, transparency and clarity for the industry. It is also a chance for the EU to set the standard in establishing a world-leading carbon removal certification framework that could be used as a blueprint across the world. Cost-effective and permanent removals, not to mention transparency (monitoring, reporting, verification), are all important operational goals. This means, among other things, that the main purpose of the certification activity must remain the promotion of carbon removals, while the certification activity itself must not become unreasonably complicated. Especially in the case of technological removals, the cost of investment and of operating the equipment for technological removals is on such a scale that, without any reward for the removal, it is difficult to see any investment taking place. Clear guidelines, on how various types of removal certificate can and cannot be used, are therefore necessary.

Background

The EU legislation on Ecodesign and Energy Labelling aims at improving environmental performance and setting minimum mandatory requirements for the energy efficiency of products. It helps eliminate the least performing products on the market and it contributes to the EU’s 2020 energy efficiency objective.

Bioenergy installations

When it comes to biomass installations, two groups of products are subject to eco-design requirements:

• Solid fuel boilers with a rated heat output of 500 kW or lower (Eco-design Directive Lot 15)
• Local space heaters with a nominal heat output of 50 kW or lower (Eco-design Directive Lot 20)

The directives impose energy efficiency requirements, as well as emission limits for OGC, CO, NOx and PM. The same groups of biomass products are subject to eco-labelling requirements:

• Solid fuel boilers with a rated heat output of 70 kW or lower (EL Regulation Lot 15)
• Local space heaters with a nominal heat output of 50 kW or lower (EL Regulation Lot 20)

Our position

In order to ensure a decarbonised heating and cooling sector, and reduce the level of emissions from the residential sector as soon as possible, it is crucial to foster the replacement of old and inefficient heating installations with highly efficient biomass stoves and boilers. On top of this, Lot10 (air to air heat pumps) and Lot20 (local space heaters) of the Energy Labelling Regulation should not be merged, as this would provide misleading information to consumers. Considering that heat pumps and LSH are totally different products, a comparison based only on electrical efficiency would convey the wrong message.

Background

Buildings are responsible for 40% of energy consumption and 36% of CO₂ emissions in the EU. When looking at the age of the heating stock in buildings, one out of every four systems having been installed before 1992. It is vital that we modernise the existing building and heating stock, making it energy efficient and renewable. This is not only important for keeping temperature levels below 1,5°C by 2050, but also for reducing the EU’s energy import bills, reinforcing energy security and cutting energy costs for households and businesses. Given the higher ambition presented in the Fit For 55 Package, the Energy Performance of Buildings and the Energy Efficiency Directives were both under revision, together with the new Renewable Energy Directive (REDII). These files are crucial to strengthening the current EU legislative framework for a more efficient and renewable building sector.

The role of bioenergy

Bioenergy is the main source of renewable heating, with 85% of all renewable heat coming from biomass – and heating 66M households. Renewable heating coming from biomass can be produced through:

• Individual biomass stoves, used as local space heaters
• Individual biomass boilers, providing hot water and space heating for an entire house
• District heating, providing heat or combined heat with power for multiple buildings

All these solutions can include the use of wood pellets. For more information on pellets for residential heating, check our dedicated factsheet.

Our position

The residential sector is still dominated by the consumption of fossil fuels, especially gas. To achieve climate neutrality by 2050, we urgently need to decarbonise the existing heating stock and replace old heating systems with modern and more efficient ones. Both individual biomass heating systems and biomass-based heating districts are an important part of the solution, offering cheap and renewable heating while guaranteeing high efficiency and low emissions. Long-term strategies for decarbonising the building sector are needed, in order to foster a switch from fossil to renewable solutions and make Europe energy independent.

Background

The bioeconomy englobes the production of renewable biological resources and the conversion of these resources and waste streams into bio-based products and bioenergy.

In 2012, the Commission published the first bio-economy strategy with five main objectives: ensuring food security, managing natural resource sustainably, reducing dependence on non-renewable resources, mitigating and adapting to climate change, creating jobs and maintaining EU competitiveness. An updated bioeconomy strategy has been released in October 2018.

In the framework of the circular economy, the Commission decided to work on a non-binding guidance document on cascading use of woody biomass which has been published in November 2018. The document aims at providing good practices on resource efficiency for wood-working industries across Europe.

The role of bioenergy

With half a million jobs in the bioenergy sector and 96% of locally sourced biomass in the EU, bioenergy contributes to rural development and reduces the import dependence on non-renewable resources. Representing an innovative solution for the heat, electricity and transport sector, sustainably managed biomass makes an important contribution to the renewable energy objective of the European Union. Bioenergy is thus a main driver of the development of a European bio-economy.

It also provides energy to other sectors further driving the EU bioeconomy, like for example the pulp and paper producers or sawmills.

Our position

Bioenergy represents more than half of Europe’s renewable energy today – mainly from solid, woody biomass. Enacting the cascading principle into legislation could seriously distort the markets and lead to counter-productive situations, as it has been seen in some Member States already. It would also undermine national strategies to replace their fossil energy consumption.

In practice, wood-working industries and bioenergy work very well together. The symbiosis of industrial processes, such as a sawmill or a pulp mill combined with bioenergy production, can increase resource efficiency as residues are used instead of ending up as waste. How this industrial symbiosis exactly looks like depends on the local needs and circumstances and should thus not be influenced by rigid implementation of the cascading principle in legislation.

Background

In the framework of the Clean Air Programme (2013), the European Commission has established a series of measures to improve EU’s air quality. Some measures should be taken at national level (NEC Directive) and some measures are taken at EU level (limitation of emissions through the ecodesign regulations, Medium Combustion Plants Directive and Industrial Emissions Directive).

The role of bioenergy

At national level, the new National Emissions Ceilings (NEC) Directive) entered into force on 31 December 2016. It sets 2020 and 2030 emission reduction commitments for five main air pollutants. It also ensures that the emission ceilings for 2010 set in the earlier directive remain applicable for Member States until the end of 2019. While the European Commission sets maximum emissions levels, Member States are free to take the appropriate measures best fitting their local circumstances.

At EU level, three directives are directly limiting emissions from bioenergy installations.

• Small scale installations are regulated with the ecodesign directives.
• Medium-scale installations in the range of 1-50 MW. The Medium Combustion Plant Directive regulates emissions of SO2, NOx and dust into the air with the aim of reducing those emissions and the risks to human health and the environment they may cause. It also lays down rules to monitor emissions of carbon monoxide (CO).

The emission limit values set in the MCP Directive will have to be applied from 20 December 2018 for new plants and by 2025 or 2030 for existing plants, depending on their size. There is some flexibility for biomass installations.

• Large-scale installations above 50 MW. Chapter III (with Annex V) of the Industrial Emission Directive sets out special provisions for certain pollutant emissions from combustion plants with a total rated thermal input equal to or greater than 50 MW, irrespective of the type of fuel used. Limit values must be based on the Best Available Techniques (BAT) summarized in a BAT Reference Document (BREFs).

Our position

In order to improve EU’s air quality, it is important that Member States fully implement the set of existing legislations. The bioenergy industry is committed to provide and use efficient technologies largely complying with emissions requirements. Member States should be incentivized to replace old and inefficient installations with modern highly efficient bioenergy installations.

Background

Forestry is a national competence even though EU environmental, agricultural and energy policies do concern forestry.
In 2013, the EU institutions adopted the EU Timber Regulation which prohibits illegally harvested timber, and products derived from such timber, from entering the EU market. In order to harmonise with legislation that governs timber from outside the EU, the EU is in the process of adopting the EU Deforestation and Forest Degradation Regulation (EUDR).
In 2021, the Commission adopted a new  EU strategy for forests which outlines different goals and priorities and calls on the Member States to develop policies that support sustainable forest management.  The European Commission, Member States and Stakeholders will develop objective, ambitious and demonstrable EU sustainable forest management criteria that can be applied regardless of the end use of forest biomass. The forestry sector is also covered at EU level by the Land Use, Land Use Change and Forestry (LULUCF) Regulation. In 2018, the LULUCF-Regulation set the binding commitment that total emissions from forestry are balanced and do not exceed CO₂ removals.

The role of biomass

Forest biomass is the most important bioenergy source and represents more than two thirds of EU bioenergy consumption. Wood fuels include wood chips, wood pellets and wood logs. For environmental and economic reasons, 74% of the primary material for pellets and 62% of the primary material for wood-for –energy-uses are by-products like bark, saw dust and wood chips from sawmills, pulp mills and wood-working industries.

Our position

Sustainable forest management is essential to guaranteeing that biomass used for energy purposes is sustainable. Sustainable forest management is ensured by national legislation, international commitments as well as voluntary certifications. Based on this existing framework, the Renewable Energy Directive introduces mandatory criteria for forest biomass, which needs to be respected via national laws and enforcement systems.