Bioenergia ry - the Bioenergy Association of Finland

Bioenergia ry the Bioenergy Association of Finland believes that the EUs bio- and circular economy plans should promote development of EUs productivity, where the Union faces significant challenges compared to competitor countries. Ideally, new bio- and circular products will increase the added value and employment of the European economy and reduce its environmental footprint.

Bioenergia ry - The Bioenergy Association of Finland’s contribution to the public consultation on the Industrial Decarbonisation Accelerator Act Bioenergia ry – the Bioenergy Association of Finland represents the interests of Finland's bioenergy and biochar sectors. We welcome the European Commission's initiative to strengthen Europe's industrial competitiveness while accelerating industrial decarbonisation.

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

Bioenergy Association of Finland welcomes the opportunity to contribute to the simplification of the Taxonomy technical screening criteria. Sustainable bioenergy plays a key role in the overall bioeconomy by valorising underutilised feedstock along the value chain and supplying reliable, around-the-clock energy.

Bioenergia ry the Bioenergy Association of Finland supports the objectives of the Directive on substantiation and communication of explicit environmental claims. It is important to clarify the rules for environmental claims in the EU and to prevent greenwashing of products and services.

The proposed initiative prepares legislative instrument for faster roll-out of so called zero emissions vehicles (ZEV) in the EU. The initiative would diminish the scope of the Clean Vehicles by concentrating only on ZEVs, instead of all clean vehicles defined by the revised Clean Vehicles Directive.

The Carbon Border Adjustment Mechanism (CBAM) was agreed in 2023 and the trading of CBAM certificates is about to start on January 1st 2026. Omnibus I package simplified the participation requirements in 2025 by limiting the scope of the CBAM to larger imports.

Bioenergy Association of Finland welcomes the overall aim of the Biotech Act II to strengthen Europes bioeconomy and industrial competitiveness. The initiative should build on clear framework conditions for sustainable bio-based value chains, support investment certainty, and accelerate the deployment of bio-based solutions that contribute to economic growth, decarbonisation, circularity, and European resilience.

Bioenergia ry the Bioenergy Association of Finland welcomes the initiative to evaluate the Renewable Energy Directive for the next decade. The EU has recently agreed a new binding climate target for 2040 in the EU Climate Law. In the coming months, several legislations will be introduced to implement this target.

Bioenergia ry the Bioenergy Association of Finland - welcomes the continued recognition of bioenergy in the Draft Climate Delegated Act of the Taxonomy Regulation. The line taken previously and now supported in the draft has been confirmed by two European Court of Justice case rulings.

Bioenergia ry - the Bioenergy Association of Finland - supports the amendment of Annex I to the Deforestation Regulation to clarify the commodities under Regulation (EU) 2023/1115. While we acknowledge the importance of avoiding deforestation and forest degradation to prevent species and habitat loss, and to mitigate and adapt to climate change, we understand and support the goal of avoiding unnecessary…

The Bioenergy Association of Finland strongly supports the Commissions legislative initiative regarding CO2 transportation infrastructure and markets and appreciates the opportunity to contribute. The swift emergence of CO2 infrastructure and a well-functioning EU market for CO2 are crucial to enable the EU to reach its climate targets and to foster competitive development of carbon management value chains.

The CO2 emission standard regulation has not been successfull in delivering progress towards the objectives. It has, on the contrary, caused major uncertainty for the end customers and limited their choices for cutting climate impact of transportation. From the Finnish point of view, CO2 standard development has led to discrediting of ICE in the near future.

The update of the EU Climate Law has now entered into force. Bioenergia ry the Bioenergy Association of Finland believes that reducing emissions must be at the core of implementing the EU Climate Law. The use of international emission units must be enabled within the framework of the EU Climate Law as part of the implementing legislation.

Bioenergia ry the Bioenergy Association of Finland welcomes the initiative to evaluate the Energy Efficiency Directive for the next decade. The EU has recently agreed a new binding climate target for 2040 in the EU Climate Law. In the coming months, several legislations will be introduced to implement this target.

The proposed regulation aims foremost at increasing the resilience of the European forests. This aim is supported by the Bioenergy Association of Finland. Resilience and diversity are a prerequisite for healthy forests that sequester carbon and provide multiple products and services to the society. Energy is one of these services.

Bioenergia ry the Bioenergy Association of Finland - considers that the primary function of the Governance Regulation should be to serve as a management dashboard for both the Member States and the Commission (which analyses aggregated data from the Member States) in the planning, reporting, and monitoring of energy and climate policy.

Bioenergia ry the Bioenergy Association of Finland welcomes the Commissions initiative to revise EUs energy security framework. We believe that in addition to the identified focus areas, it is also essential to consider the energy security of: (1) the heating system as a whole, not only electricity and gas supply, and (2) the transport system.

The update of the EU Climate Law has now entered into force. Bioenergia ry the Bioenergy Association of Finland believes that reducing emissions must be at the core of implementing the EU Climate Law. The association underlines the importance of EUs emissions trading systems in implementation of the EU Climate Law.

Bioenergia ry - the Bioenergy Association of Finland represents the bioenergy sector in Finland - including liquid and gaseous renewable fuels. Our main message is that the draft regulation should be suspended and re-evaluated with extra time. The deadline for application should be postponed until January 1, 2026. See attachment for more details.

Growing Media Finland acknowledges that LULUCF removals must be in the toolbox of reaching the 2040 and 2050 climate targets. However, the track record since 2018 in practical carrying out of LULUCF regulation has not been very encouraging starting from its overall target of 310 Mt for the EU in 2030, which is unrealistic due to many uncertainties in forest growth, inventory data and methodological misconceptions…

It is clear that LULUCF removals have a role to play for the purpose of reaching the 2030, 2040 and 2050 climate targets. At the same time, Bioenergia ry the Bioenergy Association of Finland strongly supports the starting point in the Commissions communication (February 2024) that the role of technological carbon sinks needs to become more apparent after 2030. The LULUCF regulation does offer room for improvement.