Bio-based technologies and materials are crucial for the transformation of the EU industry and can help unlock new markets for EU products and technologies. Achieving the climate neutrality goals set and upheld by the EU requires embracing a broad and sustainable use of biomass. Biomass-based materials are fundamental to Europe’s industrial transformation. Thus, Europe needs to secure biomass accessibility and lead in defining the boundaries of biomass of consumption through easy to adopt and firm standards.
To achieve these goals, regulatory measures, such as quotas for sustainable carbon in products, to stimulate market demand of bio-based solutions need to be implemented linked to a robust and pragmatic sustainability framework that fosters the scale-up of renewable chemicals and materials, avoids the complexity and inefficiencies of existing regulations, leverages proven voluntary certification schemes, and ensures feedstock choices remain market-driven and sustainability-focused is needed.
It is imperative to define robust sustainability criteria for a new bioeconomy regulatory framework and for the critical role biomass plays in Europe's decarbonization pathway. Therefore, we endorse obligatory sustainability criteria that are linked to support mechanisms such as quotas for sustainable carbon in products. It must be underlined that these criteria shall apply in regulated markets: Other non-regulated markets, such as paper, fibers and construction materials, for which voluntary sustainability concepts have proven reliable shall therefore remain independent.
We recognize that certain elements of the Renewable Energy Directive (RED), especially when it comes to agricultural biomasses and a third-party certification scheme set-up can serve as a foundation for building sustainability criteria. At the same time, we are cautious regarding the complex market access approach taken by RED as this could hinder an effective and competitive scale-up of biomass-based chemicals production.
What it takes to ensure a pragmatic and effective sustainability framework:
1. Regulation and accompanying sustainability criteria must enable and facilitate – not hinder - the scale up of renewable chemicals and materials to avoid the risk of slowing down critical investments and delaying innovation at a time when rapid progress is essential.
The RED in its overall approach aims to limit the use of biomass for energy purposes, especially those types of biomass that are suitable for material use. Against the backdrop of a cascading use this approach this is stringent. Applying the same set of criteria for material use itself appears contradictory. To facilitate a broad ramp-up of bioeconomy investments, the options of sustainably available biomasses suited for material use must grow accordingly. Thus, policy needs to proactively create conditions that expand, rather than restrict, sustainable biomass use across all relevant sectors.
2. We need a tailored, fit-for-purpose approach for the chemical and material sectors.
Building on the lessons learned from the energy sector, it is essential to recognize that these sectors involve a much broader variety of feedstocks and products, requiring solutions that are adapted to their specific complexities and needs. The bioenergy sector is a straightforward value chain, often in direct relation between source and energy conversion. Material sectors have much longer value chains comprising a multitude of chemical formulations and corresponding feedstocks. Excluding sustainably available biomasses like industrial roundwood would consequently exclude a multitude of different intermediate chemicals derived from this feedstock in countless value chains, restricting sustainable choices for producers and customers alike. The EU must therefore avoid counterproductive measures that could hinder innovation and industrial competitiveness. Simply transposing existing systems would risk entrenching inefficiencies and regulatory obstacles. For example, the Renewable Energy Directive (RED) has created complexity without fully preventing market distortion or fraud. While RED sustainability criteria served a specific purpose for the energy sector, they resulted in highly complex systems that proved challenging to administer and did not fully succeed in preventing market distortions or fraudulent practices. Applying the very same systems to regulated material sectors would likely replicate these issues, rather than resolve them.
3. Existing and proven voluntary schemes need to be part of the solution.
Instead of introducing an additional detailed and cumbersome compliance approach by replicating RED for regulated material applications, the future framework should rely on existing voluntary sustainability certification schemes that have already proven effective. These established schemes not only uphold high sustainability standards but can also significantly contribute to consumer trust and acceptance. EU-approved voluntary schemes such as ISCC EU ensure flexibility and credibility without imposing an overwhelming administrative burden. The reliance on sustainability certification systems widely accepted in the market, such as PEFC and FSCTM, has proven trustworthy and contributes significantly to maintaining a high, continuously updated sustainability standard without incurring additional costs for land users and actors along the value chain. The current voluntary sustainability certification systems for the chemical industry such as ISCC Plus are successfully operating today with strong acceptance, contributing significantly to transparency and manageability. Introducing additional, new criteria for landowners and market participants risks creating precisely the kind of regulatory complexity that the EU Commission has committed to reducing. Such measures could lead to increased administrative burdens, new reporting duties not connected to competitiveness or business success but to legal uncertainty, and potential vulnerabilities in extended audit chains.
4. Sustainability criteria should build on existing frameworks, but feedstock choices must rely on market availability.
A robust sustainability framework should intelligently integrate existing regulations and voluntary certification schemes to avoid duplication and administrative redundancy. However, any new regulation must not predetermine the choice of biomass feedstocks through prior regulatory approvals. Instead, feedstock selection should remain market-driven, based on availability and proven sustainability, allowing industries to optimize their raw material use dynamically and efficiently. Restrictive lists of allowed feedstocks would risk hampering innovation and efficiency, which would be fundamentally at odds with the EU’s strategic goals.