Bioenergy Europe calls for coherence and investment certainty in EU Taxonomy review
Our contribution to the EU Taxonomy review
Bioenergy Europe has submitted its contribution to the European Commission’s review of the EU Taxonomy Climate Delegated Act, welcoming the continued recognition of bioenergy within the sustainable finance framework while calling for greater legal clarity and consistency with existing EU legislation.
The contribution supports the Commission’s efforts to align the Taxonomy with the revised Renewable Energy Directive (RED III), particularly regarding sustainability criteria for biomass. At the same time, Bioenergy Europe warns that some proposed changes risk introducing additional restrictions that go beyond clarification and could negatively affect investor confidence and access to Taxonomy-aligned finance.
A key concern relates to the introduction of a new “do no significant harm” (DNSH) condition linked to the circular economy principle in the main bioenergy sections of Annex I. The draft text would exclude certain woody biomass feedstocks, including industrial-grade roundwood, from Taxonomy-aligned activities. Bioenergy Europe argues that this would effectively create new restrictions that are neither proportionate nor fully aligned with the implementation logic of RED III.
The association also stresses that the cascading principle should remain a flexible and context-specific resource-efficiency concept, taking into account local conditions, existing industrial structures and market realities across Member States.
In addition, Bioenergy Europe calls for greater consistency in the treatment of biomass technologies across the Taxonomy framework. While renewable biomass manufacturing activities are already recognised, the draft delegated act does not sufficiently include the installation, maintenance and repair of biomass technologies within enabling activities.
The contribution further highlights the need to revise technical wording related to medium combustion plants to ensure consistency with the full compliance framework established under existing EU legislation.
Overall, Bioenergy Europe underlines that the EU Taxonomy should support sustainable investments and provide predictable conditions for renewable energy deployment, while remaining coherent with the broader EU climate and energy framework.
