Beta Analytic

This comment is intended to recommend that the proposed bioeconomy framework include considerations regarding the source of the carbon use, reused and recycled within the Circular Economy Act and require the carbon-14 testing to determine the biomass-derived portions of products seeking the recognition of the renewable share, and to calculate GHG emissions savings caused by the adoption of biomass-derived products.

This comment recommends that the EU look into incentivising the growing role of the biomanufacturing industry under the EU public procurement rules. This is particularly crucial to incentivise the development of the biobased and biogenic products in the EU and provide a strong market incentive for biomanufacturing investment in the EU.

Proposal for a Directive of the European Parliament and of the Council on Substantiation and Communication of explicit environmental claims (Green Claims Directive) Docket ID No. COM (2023)166 This comment provides recommendations in response to the European Commission's proposal for a Directive on Green Claims specifically regarding the use of biobased testing (carbon-14 analysis) under methods such as ASTM D6866…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

This comment recommends that the EU adopt a unified definition of biobased products and materials following the well-recognised and scientifically Carbon-14 standards (ASTM D6866 and European equivalents). This is particularly crucial to incentivise the development of the biobased products and biotechnologies in the EU and provide a strong market incentive for biomanufacturing investment in the EU, especially in the…

This comment recommends using biogenic content testing (Carbon-14) to determine the biogenic carbon content of CO2 emissions embedded into CBAM products and to calculate emissions savings under the CBAM framework.

This comment recommends using biogenic content testing (Carbon-14) to determine the biogenic carbon content of CO2 captured and transported under a potential legislative proposal stemming from this call for evidence.

This comment recommends that the use of emissions factors under the RED directive should be coupled with direct measurements using Carbon-14 testing, to ensure that the biomass-derived portion of biofuels and biomass-fuels is accurately determined before applying emissions factors, especially for co-processed fuels and imported fuels.

This comment intends to address the possible use of international carbon credits to fulfill the EUs 2040 Climate targets. However, it aims to insist that international credits, if used to fulfill the EUs climate targets, should be issued and awarded under criteria that are the same and/or equivalent to EU criteria and best international practice to avoid risks of greenwashing and fraud.

We welcome the extension of the data included in the Union Database to cover relevant data from the point of production or collection of the raw material used for fuel production. However, as Article 31a(2)s purpose is to improve the traceability of data along the entire supply chain, it is essential to ensure that the data reported are accurate.