FSC and EU Renewable Energy Rules

FSC has shared three recommendations with the EU Commission on the REDII revision process, and in particular on how to make sure that woody biomass are sourced in line with sustainability limits.

Context and Goals of the EU Initiative

The energy sector is responsible for more than 75 per cent of the EU’s greenhouse gas emissions (GHG). Renewable energy has a key role in tackling climate change by reducing the EU’s dependency on imported fossil fuels.

Under the European Green Deal, the EU Commission has committed to reduce the EU’s GHG by at least 55 per cent by 2030 - and ultimately become climate neutral by 2050. In this framework, the EU Commission has proposed a revision of the Renewable Energy Directive (REDII) to align it with the EU’s increased climate ambition.

The EU Renewable Energy Directive

The Renewable Energy Directive is the legal framework for the development of renewable energy across the EU. The first Renewable Energy Directive (RED) entered into force in 2009 and set a target of 20 per cent renewables in the EU energy mix by 2020. In 2018, the recast Renewable Energy Directive (REDII) entered into force and set a new binding target of 32 per cent renewables in the EU energy mix by 2030, which is likely to be further increased.

The REDII Sustainability Criteria and the role of Voluntary Schemes

The RED II defines a series of sustainability and GHG emission criteria that operators have must comply with to be counted towards the overall 32 per cent target and to be eligible for financial support by public authorities. Some of these criteria are the same as in the original RED, while others are new or reformulated.

Voluntary and national certification schemes of EU countries help operators to verify that energy produced from biofuel (bioliquid and/ or biomass) are sustainably produced and sourced. By using schemes that are recognized by the European Commission, operators can ensure that their use of biofuel complies with the EU sustainability criteria (article 29 REDII).

Several schemes, such as FSC, also consider additional sustainability aspects such as soil, water, and social criteria. While the schemes are run privately, the European Commission can recognize them as an accepted implementation tool within REDII. FSC is currently assessing and monitoring the upcoming rules for recognition and their implications on FSC’s system.

In addition, it is worth noting that the recognition by the Commission is not a pre-requisite for certification. EU countries may accept voluntary schemes as sufficient evidence if the EU Member States' competent authorities are confident about the quality of these certification schemes.

REDII and Woody Biomass for Energy Production

RED II introduced sustainability criteria for forestry feedstocks as well as GHG criteria for solid and gaseous biomass fuels. This choice triggered a strong response from civil society and academia stressing that forest bioenergy is not climate friendly. Consequently, in the new EU Biodiversity Strategy for 2030 the EU Commission stressed the need to assess biomass supply and demand and the related sustainability issues of this value chain.

In response to this, in 2021, the EU Commission Joint Research Center (JRC), an independent body providing scientific advice and support to EU policy, published a report called “The use of woody biomass for energy production in the EU”. The report highlights “win-win” management practices to use woody biomass for energy production in line with sustainability limits. In this context, robust certification schemes are considered a necessary mitigation measure.

The REDII Revision Process and FSC’s Position

As a first step in the EU REDII revision process, the EU Commission published a  roadmap  in August 2020. A  public consultation  was launched afterwards and a short  summary  was published in March 2021. FSC has engaged in the initiative and shared feedback, summarized below.

FSC believes that forest bioenergy should be produced in line with sustainability limits, as highlighted in the JRC report, to support the EU climate and energy targets. For this, FSC welcomes the EU Commission proposal aimed at strengthening the sustainability criteria for forest biomass so to align them with the new EU’s Biodiversity Strategy.

Moreover, FSC is strongly in favor of the “cascading use of wood” principle because re-using wood wastes for bioenergy helps reduce the demand pressure on forests. This is also in line with the FSC’s 2021-2026 Strategy, which promotes responsible forest stewardship in a more holistic sense.

Our recommendations on the EU Commission’s proposal are highlighted below, as well as in the paper at the end of this page. FSC recommends to:

1. Reinforce the REDII sustainability criteria for bioenergy in line with the EU Green Deal climate ambition

2. Prioritize the “cascading use of wood” principle and phase out subsidies for burning any primary woody biomass

3. Move from the risk-based approach to the precautionary approach so that the risk assessment can focus on forest holding (instead of the much broader sourcing area) and mitigation measures, such as FSC certification, are always required.

For further questions please contact:

• For the overall FSC’s position on REDII, FSC’s EU Affairs Manager, Matteo Mascolo: m.mascolo@fsc.org
• For questions concerning EU comms, FSC’s Communication Manager, Europe & CIS, Ewa Hermanowicz: e.hermanowicz@fsc.org