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 underlines a need to agree a balanced FF55 package that supports the -55 % emissions reduction rather than a wide set of other goals. It is counter-productive and very disappointing that the Commission decided to open REDIII biomass sustainability criteria in its proposal. The proposal does not support creating negative emissions in the EU.

Bioenergy accounts for almost 60% of the current EU renewable energy consumption and according to the European Commission Long Term strategic vision , and other scientific literature, its contribution to the EU energy mix can grow in the next decades through an improved mobilisation of sustainable feedstocks.

Bioenergia ry, the Bioenergy Association of Finland, believes that favouring reusable packaging at the expense of recyclable alternatives risks promoting fossil-based material cycles vs. bio-based material cycles.Such an approach fails to identify the benefits of replacing fossil materials.

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.

The Bioenergy Association of Finland sees energy efficiency as paramount for the resilience of the European energy system. Building sector is very versatile spanning from urban public buildings to rural residential buildings. Therefore, it is crucial to find efficiency solutions to serve all building types.

Bioenergy Association of Finland considers that general emission reduction targets in the ETS and ESR sectors should be the main drivers for action in companies and member state policy actions. Higher emission targets would bring concrete efficiency gains, as they indirectly incentivise improving energy performance, either through building renovation, renewing current heating systems, or transforming the energy…

May 1st, 2020 Feedback to European Commission’s Proposal for EU Climate Law Bioenergia ry - the Bioenergy Association of Finland welcomes the proposal for EU’s Climate Law as an overall legislative framework to foster and guide climate change mitigation and adaptation activities. We fully support the aim of a climate neutral EU by 2050.

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

February 06, 2020 FEEDBACK ON EUROPEAN CLIMATE LAW – ACHIEVING CLIMATE NEUTRALITY BY 2050 We envision a just and prosperous EU with modern, resource-efficient and competitive economy. The natural capital of the EU needs to be conserved, fostered, and increased while simultaneously maintaining the health and prosperity of EU citizens from the risks related to environmental change.

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

1 (2) July 8th, 2025 Bioenergia ry – the Bioenergy Association of Finland FEEDBACK TO THE CONSULTATION ON THE EU EMISSIONS TRADING SYSTEM (EU ETS) AND MARKET STABILITY RESERVE (MSR) REVIEW Bioenergia ry – The Bioenergy Association of Finland welcomes the opportunity to provide input to the European Commission’s consultation on the EU Emissions Trading System (ETS) and Market Stability Reserve (MSR) review.

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

Feedback on the proposal for a regulation establishing a Union certification framework for carbon removals Bioenergy ry - the Bioenergy Association of Finland welcomes the Commission’s proposal for a carbon removal certification framework. There is a wide consensus globally that the emissions reductions alone will not be sufficient for us to reach our climate goals.

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

Carbon removal solutions are necessary for the EU’s 2050 target. The recent IPCC findings are consistent with this assumption. Key observation on AR6WG3 report is that CDR-methods are valuable and even crucial in the 2030s’to prevent overshoot. Research also points out that postponing CDR beyond mid-century would substantially reduce the removal potential to almost half by end of the century.

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 Bioenergy Association of Finland supports the objectives of the EU Green Deal, including climate neutrality by 2050, healthy ecosystems in the EU, improved competitiveness for European industries and higher energy security. Development of carbon border adjustment (CBA) mechanisms requires, however, careful assessment.

Bioenergy Association of Finland supports the aims of the EU Green Deal and the objective of reducing net greenhouse gas emissions by 55 % by 2030. It is quite clear that achieving this objective also requires a significant improvement in energy efficiency around Europe.

The Bioenergy Association of Finland welcomes the Commission proposal to revise the EU ETS as part of the Fit-for-55 package. The EU ETS is an important tool to implement the enhanced 2030 Climate Target. The EU ETS has proven its ability to reduce greenhouse gas emissions in the Union. It is technology-neutral and provides plenty of flexibility for its participants to fulfill the related obligations.

The Bioenergy Association of Finland supports a well-prepared transition towards EU’s climate neutrality by 2050. Climate change is a transboundary problem, where coordinated EU action can supplement and reinforce national and local action efficiently.

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.

Bioenergy Association of Finland supports the target to reach EU climate neutrality in a socially, economically and ecologically sustainable way prior to 2050. The Association underlines the need to agree a balanced FF55 package that supports the -55 % emissions reduction goal rather than a wide set of other goals. The ETD proposal sets taxation levels based on environmental impacts as well as based on end use.

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.

The Bioenergy Association of Finland supports the aim of the EU to address biodiversity loss and the degradation of ecosystems. The general objective of the proposed legislation is to restore degraded ecosystems, in particular those with the most potential to capture and store carbon and to prevent and reduce the impact of natural and man-made disasters.

Bioenergia ry the Bioenergy Association of Finland - supports consistent progress towards the 2050 climate neutrality target in setting the EU's 2040 climate target. Despite the energy crisis and war, the EU cannot afford to jeopardize its long-term net-zero target but must proceed decisively towards it in the medium term as well.

Regarding the proposed roadmap, Bioenergia ry - the Bioenergy Association of Finland would like to highlight some key issues which need to be taken into consideration by the European Commission. As for the Inception Impact Assessment, making legislation consistent and interfaces more fluent between various regulations is welcomed, but overlapping legislation must be avoided.

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…

Public Consultation on the Net-Zero Industry Act Bioenergia ry - The Bioenergy Association of Finland supports the objective of the NetZero Industry Act (NZIA) to enhance the competitiveness of the key European industries in achieving the EU’s climate targets and energy goals.

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

The Bioenergy Association of Finland supports a well-prepared transition towards EU’s climate neutrality by 2050. We appreciate this important initiative to the Amendment of the Regulation setting CO2 emission standards for cars and vans. Transport is the only economic sector whose greenhouse gas emissions are higher than in 1990. The emissions are also growing.

The Bioenergy Association of Finland supports a well-prepared transition towards EU’s climate neutrality by 2050. Climate change is a transboundary problem, where coordinated EU action can supplement and reinforce national and local action efficiently. We appreciate this important initiative to the Amendment of the Regulation setting CO2 emission standards for cars and vans.

The Bioenergy Association of Finland welcomes the opportunity to provide feedback to this initiative. We believe regulation should be first and foremost technology-neutral by defining the target but not the technical means to achieve it. Alternative fuels are clearly an important means to reduce harmful effects of transport.

We appreciate this important initiative on sustainable aviation fuels (SAF) and the opportunity to comment. This initiative will help to achieve reductions in GHG emissions from aviation. The use of SAFs present an immediate solution with significant reduction potential.

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 Bioenergy Association of Finland welcomes the Commission proposal to revise the accounting methodology from 2026 onwards. Accounting becomes easier and more transparent and is consistent with the new formulation of the EU 2030 climate target adopted as part of the EU Climate Law. We also support the phased approach (2021-2025, 2026-2030, 2030+) the Commission has presented.

The Bioenergy Association of Finland supports a well-prepared transition towards EU’s climate neutrality by 2050. Climate change is a transboundary problem, where coordinated EU action can supplement and reinforce national and local action efficiently. A profound question in the proposed revision of the LULUCF regulation is its envisaged contribution to the enhanced EU 2030 Climate Target.

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.

We appreciate the opportunity to comment this important initiative, which supports achieving necessary GHG emission reductions in maritime transport. The use of low- and zero-carbon alternative fuels, including biofuels, presents an immediate solution with a significant reduction potential. The development and uptake of these fuels will be critical for achieving a more sustainable future for maritime transport.

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.

The Bioenergy Association of Finland welcomes the revision of the CO standards for HDVs in line with the Fit for 55 objectives and believes that a recognition of all CO emission reduction pathways along the entire value chain is critical. Decarbonisation is an immediate challenge and all options that can have a rapid impact need to be enabled.

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.

It is essential and responsible to ensure a fair energy transition in the designated ”carbon intensive areas”. The Association supports JTF with profound planning and careful preparation engaging the areas designated as soon as the final decisions will be made and the criteria will be available.

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.

We welcome this opportunity to provide feedback on the roadmap regarding the creation of a new Euro 7 emissions standard. We strongly endorse this initiative that supports the Green Deal and helps to ensure that vehicles on EU roads are clean not only during the initial assessment but over their entire lifetime at any typical usage. Any simplifications of the test procedure should be evaluated very carefully.

Bioenergy association of Finland would like to submit the following inputs concerning the revision of Ecodesign requirements for Solid-fuel Boilers. Solid fuel boilers are proven technologies that have shown significant improvements in energy efficiency through the years, using less feedstock and therefore reducing emissions.

The Bioenergy Association of Finland considers the proposed Social Climate Fund problematic from many aspects and cannot support the proposal. Member States are responsible for social policy and protection of vulnerable households. The Social Climate Fund would directly intervene with the social sector of the Member States.