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Core Theme 4: Biomass Mobilisation and Sustainability

| Highlights CT 4
CT4 Session Highlights of the 1st, 2nd, 3rd, 4th and 5th Plenary Meeting

1st Plenary Meeting, 17th-18th November 2021, Online


Session 6: Sustainability criteria for biomass fuels

Based on the results of the questionnaire, it appears that very few Member States have already fully implemented the RED II sustainability criteria for biomass fuels in the power and heating/cooling sectors. DG-ENER presented an update on bioenergy policies and other related policies while emphasizing the priority to be given to the effective implementation of REDII by MS. The REDII revision proposals strengthen the sustainability of bioenergy through (1) new land-use criteria for forest biomass (e.g. no sourcing from primary and highly biodiverse forests, peatlands, and wetlands) ; (2) application of GHG saving criteria to existing installations as well as to small-scale installations (equal or above 5 MW); (3) minimising the use of quality roundwood for energy production and undue distortive effects on the biomass raw material markets or harmful impacts on biodiversity (New Delegated Act on cascading use of biomass, no support for saw logs and veneer logs, stumps/roots ; from 2026, no support for electricity-only-installations using forest biomass). Regarding Implementing Acts, adoption processes have fallen behind the deadlines set out in REDII. The operational guidance on forest biomass criteria is still under discussion within the Committee on the Sustainability of Biofuels, Bioliquids, and Biomass fuels (which is made up of Member State representatives) as well as the Standards for voluntary schemes. Regarding other policies impacting bioenergy, several proposals in the Fit-for-55 package are interesting: EU Forest strategy (sustainability, protected areas, cascading), LULUCF regulation (carbon removals), Deforestation regulation (REDII sustainability compliance).
Session 10: Verification of compliance under RED II
Based on the results of the questionnaire, it appears again that very few Member States have already partially or fully implemented their verification system for economic operators to submit evidence of compliance with sustainability criteria for the use of biomass in the power and heating/cooling sectors. These systems could be based on Voluntary Certification Schemes (VCS) and/or National Certification Schemes (NCS). The same situation is observed regarding the integration of such a verification system into the ETS system. DG-ENER presented an update on the requirements for mass balance systems and on the process of recognition of VCS/NCS by the Commission. Germany proposed to set up a working group to exchange knowledge on mass balance systems. GUIDEHOUSE presented in more detail the current assessment process of some VCS for forest biomass. The quality of submissions varied considerably among applicants: existing biofuel schemes included very limited guidance beyond the provisions of REDII articles, and existing forestry schemes were not familiar with the assessment process but included detailed but not specific to REDII requirements. GUIDEHOUSE emphasized the importance of the approach ensuring quality and consistency across the schemes.

The Netherlands Enterprise Agency (RVO) presented the verification system implemented under its support scheme (SDE). The old national system for wood pellets installations has been adapted to indirectly comply with REDII (very few changes needed). Other installations (gasification/combustion plants using biomass other than pellets, and biogas) must comply directly with REDII requirements (“RED biomass”). Energy producers can provide evidence using the certification schemes approved by the Dutch Minister (8 today) but can also use third party verified evidence for certain criteria to reduce the administrative burden. To obtain subsidies, a annual conformity statement is issued by Conformity Assessment Bodies (CAB) recognised by the Dutch Minister to work with the new SDE verification protocol for “RED biomass”. Biomass types for which REDII only requires calculations of GHG savings and proof of waste/residue can use alternative evidence for SDE instead of EU certification (manure only, post-consumer wood waste only, municipal sewage sludge plants only). This national system will not be notified to the EC for recognition. During the discussion, Austria proposed to set up a working group with experts from the MS in charge of a national certification scheme.


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CA-RES4_PM1_Highlights CT4



2nd Plenary Meeting, 18th-19th May 2022, Online


Session 5: Availability of sustainable forest biomass

This session focused on the potential impacts of EU forest-related policies on the mobilisation of forest biomass for bioenergy purposes. In the first part of the session, DG-ENER presented the proposals for revision of REDII concerning bioenergy as well as a state-of-play of the REDII implementation (implementing regulation and transposition checks).

MS addressed many questions to the Commission regarding the practical implementation of the RED II criteria for forest biomass and are still waiting for the implementing regulation providing operational guidance to MS for forest biomass. MS are also concerned about the relatively low number of VS covering forest biomass. MS also addressed several questions via the questionnaire regarding the practical implementation of RED II criteria on forest biomass (risk-based approaches, group auditing,…) and expressed the need to continue exchange of information and best practices between MS on this topic.

DG-AGRI presented the new EU Forest Strategy for 2030, which promotes the multi-functional role of forests. Some MS have raised the risk that new barriers will emerge that will reduce the use of wood-based resources for sustainable bioenergy purposes and call for better integration of all bioenergy stakeholders in the implementation process.

DG-ENV presented the proposal for a regulation on deforestation-free products. The six commodities covered by the regulation are palm oil, beef, soy, coffee, cocoa, and wood. The new regulation will guarantee that the listed product available on the EU market do not contribute to global deforestation and forest degradation.

Some MS stressed the need to strengthen synergies with the REDII sustainability criteria in order to avoid duplication of requirements and procedures.

In the second part of the session, JRC presented the results of a recent study on the use of woody biomass for energy production in the EU and its potential impacts on biodiversity and climate change. The called for improved availability and quality of data to accurately assess the sustainability of woody biomass uses. The energy sector is the largest user of EU internal wood processing by-products. Industrial by-products and recovered wood can be expected to satisfy an increased demand from the energy sector only partially, given that these sources are also used in wood products manufacturing. The qualitative assessment of the JRC shows that there are win-win management practices options, which contribute positively to both biodiversity and climate change. Some MS called for the inclusion in future analysis of additional management practices such as those adapted to fire-prone areas.


Session 11: Sustainable biogas production

This session focused on the promotion of sustainable biogas/biomethane production and on sustainability, certification, and traceability aspects of the biogas/biomethane value chain. The results of the questionnaire revealed interesting policy developments in several MS, such as the implementation of new support schemes, a blending obligation of renewable gas for the gas grid or a renewable gas quota obligation for suppliers. National strategies are still mainly based on anaerobic digestion, but gasification is now seen in two MS as an opportunity to meet the 2030 targets. The questions concerning the GHG emissions saving were answered in a wide variety of ways, indicating that further guidance is still needed.

DG-ENER presented the promotion of biogas/biomethane under the REDII and the RePowerEU Action Plan, and EBA reflected on these plans. The biomethane target of 35 bcm by 2030 seems ambitious but achievable by using only sustainable feedstocks like manure, agricultural residues, industrial wastewater, and food waste. Also, a large contribution is foreseen for sequential crops but there are still several issues that needs clarification and harmonization. The action plan covers six pillars. The focus is on upgrading of biogas to biomethane and grid injection, this requires the regional assessment of network development and matching it with the potential of biomethane production. The action plan also covers issues like financial instruments for risk mitigation, R&D gaps, creating industrial partnerships, speeding up permitting and standardization.

DG-ENER also presented the sustainability performances of biogas pathways under REDII. The potential of sequential crops, without the need for additional land use, was highlighted. A current review of Annex IX part A is expected to broaden the scope and the update of Annexes V/VI will provide an opportunity to add new pathways for biomethane production with more feedstocks and more technological options.

In addition, for harmonization purposes, the BioGrace tool is likely to be updated by the EC and made publicly available on the EC website. Traceability issues are expected to be improved through the Union Database, which will play an important role in supporting cross-border trade and preventing double counting. The database implements the mass balancing system throughout the interconnected European grid and will cover all types of end-users.

This session showed that there is a need for clarification and harmonization on several issues (GHG emission reduction methodology and default values, traceability, cross-border trade, state aid and accounting up to the point of consumption and mitigating the risk of double counting, etc.). The proposal to organise a task force on these biomethane issues was welcomed.


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3rd Plenary Meeting, 09th-10th November 2022, Athens, Greece


Session 5: Sustainable forest biomass mobilisation

This session started with an update from DG-ENER on EU bioenergy policies with a comprehensive explanation of the forthcoming Implementing Regulation on the sustainability criteria for forest biomass and an overview of the newly adopted EC Guidance on biomass issues in the EU ETS. Difficulties in reporting on the use of sustainable biomass are to be expected in the short term.

The session continued with a presentation of a representative of the Finnish Ministry of Economic Affairs and Employment who presented Finland's ambition to reduce greenhouse gas emissions by 60% by 2030 and being carbon neutral by 2035, mainly based on bioenergy (80% of the renewable energy mix, mainly waste and residues from forest industry). This will be compatible with maintaining the Finnish forest as a carbon sink (better forest management and cascade use) and will be market-driven (no subsidies will be needed). Finland argued for more exchanges of information between Member States but also for a slowdown in harmonisation in order to take into account national specificities. Some evidence of compliance is still difficult to verify in practice (e.g. LULUCF at sourcing level) and uncertainties for economic operators are increasing due to the ongoing revision of REDII.

The session continued with an overview by DG TRADE about the current export restrictions on wood following the economic crisis and the Russian’s invasion of Ukraine.

The session concluded by a panel discussion during which questions emerged about the sustainability criteria compliance if no subsidies are needed and for non-ETS sectors.


Session 9: Biomethane roadmap to 2030

The session started with an update from DG-ENER on the REPowerEU Action Plan for Biomethane and a presentation of the new Biomethane Industrial Partnership (BIP), a public-private partnership whose objectives are to steer cooperation and to address bottlenecks (issuing recommendations, guidance, etc.) in order to reach the 35 bcm target of biomethane by 2030.

The Danish Energy Agency presented the national target to cover gas consumption with 100% green gas by 2030 (10TWh) combined with a significant decrease (40%) in gas consumption. The increase in biogas production will be made possible by specific support schemes (feed-in tariffs and tenders) and will require the adaptation of the Danish gas grid. The main biomass feedstocks will be manure and industrial waste. The Danish authorities plan to reduce the use of energy crops and ban the use of maize from 2025.

The session continued with the Dutch Ministry of Economic Affairs and Climate Policy who presented the national program to reach 2 bcm (or more) of biomethane by 2030. To achieve this target, the Netherlands is tackling existing administrative barriers (e.g. permits) and is implementing a blending obligation for energy suppliers as from 2025. Inconsistencies have also been identified between EU ETS (GoOs do count), national inventory (GoOs do not count) and REDII targets.

The session concluded by a panel discussion during which concerns were expressed about the implementation of support schemes for biogas in transport sector. Portugal, Spain and Italy also presented the progress made in their respective national strategies for biomethane.


Session 15: Joint Session CT4/CT5: supervision of certification bodies by Member States

A representative of the European Commission started this session with an update on voluntary schemes for forest biomass. Up till now 2 voluntary schemes are recognised by the Commission for forest biomass. Due to art 30-9 (REDII) and art 17 (Implementing Regulation) the role of Member States with regards to supervision of certification bodies is going to change. Main questions listed on this topic were:  1. Certification Bodies (CBs) can ask which Member State is the lead-supervisor. How to appoint the lead-supervisor between Member States?  2. Who is supervising the CB when controlling raw materials from outside EU?  3. How to deal with differences between Member States with regards to energy mix (import/export/feedstock etc.)?  These questions were already further elaborated upon by a task force consisting of several Member States. Results of the task force were presented and discussed on the basis of the following questions:  1. Cooperate with REFUREC (group regulators of biofuels) on these issues?  2. What steps do require formal decision? 3. Who is the best party to do so?  Participants concluded that cooperation between all Member States is preferred, for instance in CA-RES and via an EC Expert Group.


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4th Plenary Meeting, 24th-25th May 2023, Vienna


Session 4: Sustainable Forest biomass mobilisation

The session started with a comprehensive explanation of the Implementing Regulation 2022/2001 on the evidence for demonstrating compliance with the sustainability criteria for forest biomass and the Implementing Regulation 2022/996 on rules to verify these criteria. DG-ENER also gave an overview of the achievements of the 2020 targets. The session continued with a presentation of the main results of the questionnaire sent to participants before the session. It mainly revealed that Member States struggle to understand who is concerned by the risk-based assessment for forest biomass and how it should be done. The session continued with a presentation of the report of the Swedish Forest Agency (2019) which evaluates the compatibility of the Swedish legislation with the RED II sustainability criteria for forest biomass. The session concluded by a panel discussion about the Level A risk-based Assessment. Questions emerged about the role of Member States which may differ depending on the type of certification scheme chosen (national or voluntary), recognition by Voluntary Schemes and other Member States and updating.


Session 11: Combined Session CT4/TF-GO: Biomethane and renewable gas with the focus on gas market development

The session started with a presentation of the Spanish system of guarantees of origin for renewable gas (2022), operated by ENAGAS GTS. The system has been designed to be as standard as possible to facilitate import/export of GOs (expected to be possible by the end of 2023 through the AIB hub). GOs can be issued for biogas, biomethane and renewable gas: (a) injected into the national gas grid, (b) for off grid use (rural areas), (c) injected in isolated networks and (d) include self-consumption. Regarding sustainability, Spain is currently studying the possibility to combine POS (Proof of sustainability) and GOs into a unique certificate as well as several connection options to UDB. E-control then presented the Austrian system of guarantees of origin for renewable gas (2021). E-Control issues GOs for biomethane, hydrogen and fossil gas extracted in Austria. For off grid production, specific “green certificates” are issued instead of GOs. Regarding export/import of GOs, Austria is the first issuing body connected to AIB HUB (May 2023). Austria is currently working on the possibility to integrate the sustainability information on the GOs. A green gas quota system based on GO and “green certificates” is also in preparation. The session continued with a presentation of the main results of the questionnaire sent to participants before the session. At present, at least 10 MS have an operational system for biomethane GO injected into the gas grid and 4 GO systems are already integrating the REDII POS. However, there are still pending questions about the integration of sustainability characteristics in the GOs. It also appeared that the main tendency among the participants is to accept the separate sale of GO and gas commodity (book and claim system applied to a single mass balance system, the EU interconnected gas grids) but a link between the GO and the POS seems necessary to avoid any risk of double counting. The session continued with a presentation from DG-ENER of the state of play of the Union Database for gaseous fuels value chain. As the EU Grid is considered as a single logistical facility from a Mass-Balance perspective, only the injection and the consumption points are registered (“what, where and when”). Any “between – trade” will not be registered within the UDB. In this way, the UDB doesn’t hinder the gas commodity and GO certificate trade. The UDB will ensure the link between the POS and the GO. The DG-ENER emphasized the importance of the involvement of Member States in the UDB process. Participants stressed the importance of also directly involving the relevant national GO authorities. The session concluded with a Q&A-session about the operationalization of the UDB.


Session 13: Combined Session CT4/CT5: Verification of compliance with the REDII criteria - Final results of the Task Force on supervision by MS

The joint CT4/CT5 session was devoted to the supervision of certification bodies by Member States. During this session, the results of the Task Force on this topic, launched a year ago, were presented. The Task Force concluded that (1) several issues could be resolved via an addendum to the CIR 996/2022 clarifying the role that Member States should play in the registration of voluntary schemes, the appointment of a lead supervisor and establishing basic rules of supervision procedure / guidance to achieve harmonization ; (2) it is important, for supervision in third countries, to address the necessary access of supervisors more explicitly in the regulation ; (3) it should be possible to address tasks to Member States through a group of experts in charge of the coordination that has a formal position to the Member States and the EC; (4) a timeframe is required for the tasks of coordination and their interaction and (5) there is enough to discuss at future CA-RES meetings (the role of biomass fuels, biomethane or RFNBO’s in this framework, etc.). Most priority in time is given to the addendum to the CIR 996/2022 by the attending policy makers. The task force's work is now complete, and it will be up to the existing parties to continue the process on the basis of the priorities and actions defined by the task force.


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5th Plenary Meeting, 18th-19th October 2023, Lisbon


Session 5: Certification of waste and residue

The session started with a comprehensive presentation by DG ENER of the new Directive 2023/2413 amending Directive 2018/2001, with a focus on provisions linked to bioenergy, cascading principle, and reinforced sustainability criteria for biomass. DG ENER also gave a quick update on the implementation of RED II Directive by Member States and transposition checks by the Commission. Further the Union Bioenergy Sustainability Report was presented. The EC observed a need to improve data reporting by the Member States and clarity on requested data.

There is an increasing gap between Members States regarding the transposition of RED II into national legislation causing difficulties for some economic operators. Member States also have concerns about the scarcity of certification bodies and additional requirements of some Voluntary Schemes, not necessarily linked to RED II criteria, especially in for (mixed) waste streams.  This part of the markets seems less developed within the EU-recognised voluntary schemes. Since definitions as ‘waste’ are linked to other more national circumstances, it is more difficult for the Voluntary Schemes to apply. Companies and certifying bodies under the EU-recognised systems are confronted with complex discussions on definitions. Countries with a national system are better able to integrate sustainability and on other requirements in one system.  More interaction, and a better coordination with the ETS-frameworks seems ways forward that might bring this topic further. 


Session 13: Towards a European biomethane market

The session started with an update from DG ENER on the state of play of the promotion framework for biomethane. The Commission is currently assessing the draft updated NECPs sent by Member States and will issue recommendations by 31 December 2023. The initial assessment highlighted varying quality in reporting on biomethane production and use. There are also some inconsistencies with the “Biomethane country fiches” prepared by the Commission. This underlines the need for alignment with the Member States. The presentation continued with an overview of the planning of deliverables of the BIP (Biomethane Industrial Partnership) Task Forces. DG ENER suggested the creation of a dedicated space within the BIP only for the Member State to discuss and challenge the Task Forces’ deliverables, mainly driven by industry.  Another initiative would be to enlarge the scope to smaller companies. DG ENER concluded with a short update on the revision of Annex V and Annex VI of the revised RED II Directive on rules for calculating the GHG impacts of biofuels, bioliquids, biomass fuels. The revised version of the annexes will be submitted to public consultation by mid-2024.

The session continued with a comprehensive overview of the biomethane perspectives and strategies in Portugal. The overall potential of biomethane production is about 0.62 bcm, with an estimate of additional opportunities about 0.35-0.40 bcm by 2030. If there is an increasing ambition for the role of biomethane in Portugal, policies remain unclear and many “grey zones” still exist regarding the long-terms roles of biomethane in the Portuguese energy system. These uncertainties should be partly clarified in the “National Strategy for Biomethane”, expected by the end of 2023. In September 2023, the issuing body for guarantees of origin REN (“National Energy Networks”) updated its procedures related to renewable and low carbon gases. REN expects to be ready to issue GOs for biomethane by the first half of 2024. The presentation concluded with a short overview of the support schemes put in place at the supply side (Calls for production under the Recovery and Resilience Plan) and the demand side (auctions for injection into the gas grid).


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