A new proposal from the European Parliament would declare primary woody biomass to be unsustainable, which would heavily impact the supply of bioenergy and remove the sector’s ability to provide sustainable energy, especially renewable heat this winter.

Europe is the continent of climate action: the EU increased its already ambitious goal of cutting greenhouse gas emissions and surpassed its bold renewable targets, securing 22% renewable energy by 2020, 2% more than expected. One of the main drivers of our climate success has been bioenergy.

Sustainable bioenergy makes up nearly 60% of our renewable energy and is responsible for 21% of Europe’s domestically produced energy. More importantly, it does not rely on massive imports which threaten Europe’s energy security now more than ever. Unlike fossil gas, of which 84% comes from foreign sources and which makes up one third of the EU’s energy imports, the import rate of biomass for energy is below 4%, meaning less than 1% of all EU imports. Bioenergy is thus a crucial resource which reduces our dependency on foreign states.

Against the backdrop of a war in Europe, with skyrocketing energy prices and growing concerns that a Russian fossil fuel embargo could result in heating shortages this winter, the EP is revising the Renewable Energy Directive, with one particular proposal raising alarm. The Parliament’s environment committee (ENVI) has proposed to declare all bioenergy that uses primary woody biomass to be unsustainable and thus not renewable anymore.

But what is primary woody biomass?

It is any biomass that comes directly from a forest without being a by-product of a sawmill or other wood-processing industries. This does not just mean high-quality wood that can be used for long-lasting products, but also rotten wood, pieces that are too small for commercial use and wood that is rejected by industries because it is crooked, broken or contaminated with fungus and mold. On top of this, nearly all sustainable forest management practices generate some low-quality forest biomass, and these materials can be used to provide bioenergy, such as vital heating services.

If this material is rejected by other industries and cannot be used for solid wood products, then shouldn’t all this wood be left in the forest?

On the contrary, leaving too much unnecessary residue on the ground can increase risks for the forest. Climate change is already impacting the health of our ecosystem, and the soaring temperatures that Europe is experiencing (combined with drought-like conditions) mean that forests will continue to be under increasing pressure. The 2022 fire season is already shaping up to be worse than last year's, which was an above-average fire season. Leaving an excessive amount of deadwood in forests increases the amount of fuel available for a forest fire in warmer periods, thereby allowing for rapid spread of such fires.

Some deadwood certainly needs to be left inside forests to protect biodiversity, as already legally mandated by national law and existing provisions in the Renewable Energy Directive. There is a reason why forest policy is directly managed by Member States and not at the EU level: a spruce forest in Finland will have different needs from a beech forest in Poland or a mixed forest in Spain. Determining a one-size-fits-all approach at the European level vastly underestimates the level of diversity in forest resources that we have in Europe.

It is also incredibly difficult to predict what impact this ban would have as there is very little information on how much of the biomass being used for sustainable bioenergy comes from primary woody biomass, because this distinction is not used by industry to determine either quality or end-use. One of the few studies providing information on this is a report by the Joint Research Center, which estimated that 37% of the biomass used for bioenergy came from primary sources, but was unable to categorise 14% because industry does not collect data on this. Considering that 57,4% of Europe’s renewable energy came from bioenergy (Eurostat data, 2019) and that 70% of bioenergy uses woody biomass as its feedstock, banning the use of primary woody biomass would eliminate up to 20,5% of Europe’s renewable energy.

Most of this material would disappear from the bioeconomy due to its limited use and very low value. If it cannot be used for bioenergy, it will be discarded or left in the forest – creating greater risk for wildfires and other disasters. Since it is expensive to transport waste from such a remote area, an unfortunate alternative is to burn it in open-air fires with uncontrolled emissions.

While it might seem like a good idea to place constraints on what can be done with various raw materials, these market restrictions only succeed in limiting innovation and increasing inefficient practices. Europe has already tried regulating what can be done with several such raw materials; in Sweden, the Wood Fiber Act (lagen 1987:588 om träfiberråvara) tried to restrict the usage of certain materials so that they could not be used for bioenergy; this caused major disruptions to the market and the law was repealed six years later (p.45).

If this proposal is adopted what will the consequences be?

20% of Europe’s renewable energy will be lost, which is 4% of Europe’s total energy. Reducing the energy supply at this critical moment will drive prices up and increase energy poverty because, in the short-term, sustainable bioenergy can only be replaced with more expensive natural gas and coal. Increasing the supply of fossil fuels will likely require increasing energy imports while countries are already scrambling to increase domestic production of fossil fuels and secure new trade deals to replace Russian fossil fuels. In the REPowerEU Plan, the Commission has set the target to replace at least 155 bcm of gas from the energy mix. In comparison, primary woody biomass could replace at least 40 bcm. If the new proposal would be adopted, suppliers would now be forced to replace renewable and domestically produced bioenergy as well.

Banning primary woody biomass from being used for sustainable bioenergy would be a missed opportunity, and would be detrimental to our energy security, with the most vulnerable households already at risk of energy poverty, and to our climate ambitions because renewable energy would be replaced with fossil fuels.


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