Bioenergy Europe

Bioenergy Europe welcomes the European Commissions initiative to establish an Industrial Accelerator Act to accelerate industrial decarbonization and strengthen EU manufacturing, particularly by reducing permitting delays and creating more predictable investment conditions.

Bioenergy Europe welcomes the European Commission initiative evaluating the possible revision of the Renewable Energy Directive ((EU) 2018/2001). The achievement of the carbon-neutrality objective by 2050 will require a prompt adjustment of the mid-term climate and energy objectives measures.

Bioenergy Europe welcomes the opportunity to contribute to the simplification of the Taxonomy technical screening criteria. To achieve Europes energy and climate goals it is pivotal to ensure regulatory stability and consistency among interconnected policy files.

Bioenergy Europe supports the highest level of ambition in the decarbonisation of building sector in order to achieve carbon neutrality by 2050. Consistently with this position, we have supported the increased use of renewable energy in the public consultations following the presentation of the European Green Deal as the main pathway to decarbonise domestic heating and cooling.

Bioenergy Europe welcomes the European Commission’s efforts to put sustainability at the heart of its policies. The European Green Deal, presented on 11 December 2019, is a well-balanced growth plan which will steer the transition toward a carbon-neutral economy. Bioenergy Europe supports the intention to enshrine the principle of carbon-neutrality in binding legislation.

Bioenergy Europe welcomes the EC's proposal for a Carbon Removal Certification Framework put forward in November last year with the aim to develop a trustworthy system to quantify and valorize removals and achieve climate neutrality by 2050. The proposal outlines the start of a process, and we support a sound and harmonized governance framework that is much needed for this essential sector.

Carbon Dioxide Removals are necessary, alongside carbon reductions, to achieve the EU’s 2050 target. The Intergovernmental Panel on Climate Change’s (IPCC) findings underscore this assumption: within their 116 scenarios that limited global warming to 1.5°C, negative emission technologies were included in 101 scenarios.

Bioenergy Europe welcomes the opportunity to provide feedback to the EU ETS and MSR review. As a representative of the European bioenergy sector, we strongly support the EUs 2040 climate target and the transition to net-zero by 2050. We call for the inclusion of permanent carbon removals in the EU ETS, in line with the "like-for-like" principle.

Bioenergy Europe welcomes the European Commission’s proposal for the recast of the Energy Efficiency Directive (EED). The draft shows a renewed interest towards heat decarbonisation, listing concrete measures to further promote the uptake of renewable heat solutions such as sustainable biomass.

Bioenergy Europe welcomes the opportunity to contribute to the public consultation on the revision of the Energy Efficiency Directive. Bioenergy Europe believes that to reach the 2050 decarbonisation targets, 2030 climate and energy objectives must be revised. The penetration of renewables in the heating sector must be prioritised by 2030 to decarbonise Europe’s building stock.

The achievement of the more ambitious GHG emission reductions target, eventually leading to reaching climate neutrality by 2050, necessitates an adjustment of the EU ETS functioning. The 'polluter pays' principle should be at the core of the EU energy and climate policies, while covering all emissions of fossil fuel combustion and integrating them in the EU ETS, would present important benefits in terms of…

Bioenergy Europe welcomes the opportunity to comment on the Roadmap on the Amendment of the EU Emissions Trading System. It is a matter of great urgency to strengthen the current ETS by aligning the emissions ceiling with the increased target of at least 55% GHG reduction for 2030, and to further pathways towards carbon neutrality by 2050.

Bioenergy Europe welcomes the ambition of the Biotech Act II to strengthen Europes bioeconomy and industrial competitiveness. The Act should adopt an inclusive, technology-neutral approach to biomanufacturing, recognising various sustainable biomass conversion pathways, and aim to reduce regulatory fragmentation across Member States by promoting harmonisation, predictability, and efficient market access for…

Achieving the ambitious climate and energy targets envisaged within the European Green Deal and the improvement of the internal market functioning require revision of the Energy Taxation Directive (ETD) which has not undergone any changes since 2003.

Bioenergy Europe would welcome the prompt revision of the Energy Taxation Directive (ETD). At the time of its adoption, the ETD represented a positive contribution to the EU’s legislative framework. As it has remained unchanged since 2003, it no longer reflects the evolution and progress in technologies, energy markets and the EU legislative framework in response to the climate emergency.

Bioenergy Europe is happy to comment on the review of the Renewable Energy legal framework after 2030 and supports an updated infrastructure that supports a reliable, affordable, homegrown, fully defossilised European energy system.

Bioenergy Europe welcomes the continued recognition of bioenergy in the Draft Climate Delegated Act of the Taxonomy Regulation and supports the European Commissions efforts to improve clarity and coherence with existing EU legislation.

Bioenergy Europe welcomes the Commissions proposal to amend the Climate Law with a 2040 target of at least 90% net GHG reduction, recognising it as a crucial milestone to remain on a science-based path to climate neutrality by 2050 and to safeguard the EUs credibility under the Paris Agreement.

Bioenergy Europe supports the EU climate targets for industrial decarbonisation, preventing carbon leakage, and ensuring a level playing field throughout the value chain for the whole European industry. However, as CBAM is implemented and carbon-related costs are reflected in materials such as steel and aluminium, it is important to review potential unintended impacts on the competitiveness of downstream…

Bioenergy Europe welcomes the revision of the Industrial Emissions Directive (IED) and higher ambition that the Commission is showing in this context. However, the continued exclusion of construction and demolition waste in the revised definition of “Biomass” (Art. 3 (31)) risks leading to the non-recognition of wood waste as biomass.

Bioenergy Europe would welcome the revision of the Industrial Emissions Directive (ITD). The transition towards carbon neutral economy requires an appropriate legal framework providing a legal certainty for all participants of the market.

As the trade association representing the European bioenergy sector, Bioenergy Europe welcomes this opportunity to comment on the amendments to Annex I of EUDR. In particular, we would like to highlight three suggested revisions that are in light with the goal of the European Commission to reduce administrative burden to operators and competent authorities, while maintaining the focus of EUDR in the fight against…

As the trade association representing the European bioenergy sector, Bioenergy Europe welcomes this opportunity to comment on the amendments to Annex I of EUDR. In particular, we would like to highlight three suggested revisions that are in light with the goal of the European Commission to reduce administrative burden to operators and competent authorities, while maintaining the focus of EUDR in the fight against…

Bioenergy Europe supports the objective of the Net-Zero Industry Act (NZIA) which seeks to enhance the competitiveness of European net-zero industries which will be vital to achieving the EUs ambitious climate and energy goals.

Bioenergy Europe welcomes the revision of the EU Heating and Cooling Strategy and stresses the importance of prioritising clean heat as a cornerstone in the energy transition. Decarbonisation of heating is key for a climate neutral and resilient Europe, and the strategy should encompass all sectors: private households, district heating and process-heat in industry and businesses.

Bioenergy Europe welcomes the opportunity to provide feedback on the proposed revision of the Greenhouse Gas (GHG) emission saving methodology under Annex V and VI of the Renewable Energy Directive (REDIII). While we support the Commissions efforts to update the frameworkspecifically by including previously missing segments such as the accounting of permanent carbon storage (BECCS) and default values for…

Bioenergy Europe welcomes the opportunity to provide feedback on the proposed LULUCF regulation. Overall, Bioenergy Europe is concerned that the current draft is neither suited to support the transition to a bioeconomy nor to phase out the use of fossil materials and energy.

Bioenergy Europe welcomes the initiative to align LULUCF rules with the new 2030 climate target, paving the way for carbon neutrality by 2050. While the mention of carbon farming initiative within the Farm to Fork Strategy and the certification of carbon removals part of the Circular Economy Action Plan are relevant, the roadmap does not divulge details on the main drivers for land use: the Common Agricultural…

Bioenergy Europe would like to submit the following inputs concerning the revision of Ecodesign requirements for Solid-fuel Local Space Heaters (LSHs) First of all, a new calculation for seasonal efficiency is needed. When measuring efficiency, renewability must be taken into consideration to ensure a fair evaluation and comparability for all appliances in the market.

Bioenergy Europe, the voice of the European bioenergy industry, welcomes the opportunity to provide feedback on the proposed revision of the Governance of the Energy Union and Climate Action Regulation. As the EU looks toward the post-2030 horizon, it is imperative to establish a stable, reliable, and coherent policy framework that empowers the bioenergy sector to fully contribute to Europes climate-neutrality…

Bioenergy Europe welcomes the Commissions initiative to review the Energy Security Framework. It offers the opportunity to align energy security governance with the EUs decarbonisation goals and ensure that sustainable bioenergy is fully recognised as an essential and growing contributor to Europes energy resilience.

Bioenergy Europe, the European association for the bioenergy sector, welcomes the opportunity to provide feedback on the National Targets and Flexibilities in the context of the post-2030 framework. We fully support the Commissions efforts to update the energy policy infrastructure for the decade ahead.

Bioenergy Europe welcomes the plan for the establishment of Just Transition Mechanism (JTM) and the proposal of its core element, the Just Transition Fund (JTF). This is a much-needed instrument, helping to address existing and future socio-economic challenges the transition towards a carbon-neutral economy will pose.

Comment on the Evaluation of the Land-Use, Land-Use Change, and Forestry Regulation Bioenergy Europe welcomes the opportunity to provide feedback on the Land-Use, Land-Use Change, and Forestry (LULUCF) regulation.

In the context of the Commissions initiative for an Omnibus for energy-related products, Bioenergy Europe calls upon the European Commission to consider the following points: 1. Prolongation of the transitional provisions for products under the Ecodesign Directive.

The Commission, as part of the energy labelling regulations revision, has recently proposed to merge, into a single scale, the energy labelling of all generators which, as a function, offer space heating (Lot 10 and Lot 20). The proposal also provides for a classification scale (A-G) shared by all technologies.

Bioenergy Europe 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 in a better way and therefore reducing emissions.