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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