Bioenergy Europe Feedback on Simplification of administrative burdens in environmental legislation

Bioenergy Europe has submitted its feedback to the European Commission’s public consultation on the simplification of administrative burdens in environmental legislation. We welcome this initiative, which is an important step to reduce unnecessary complexity while maintaining high environmental ambition. Here are the main recommendations from the Bioenergy sector:

Targeted improvements to the EU Deforestation Regulation (EUDR)

We stress the need to make EUDR implementation more practical and risk-based by:

• Introducing proportionality by risk level, exempting low-risk countries from redundant due diligence.
• Applying thresholds and transition periods, preventing small imports from triggering heavy obligations and allowing two years for traceability systems to be set up.
• Adapting geolocation rules for residues, recognising the mixed-origin nature of sawmill by-products and other secondary raw materials.
• Clarifying forest degradation definitions and methods, ensuring clear and harmonised guidance for operators.

Simplifications under REDIII and IED

To further reduce burdens while maintaining sustainability safeguards, Bioenergy Europe calls for:

• Deleting the “industrial-grade roundwood” definition, already covered by the cascading principle.
• Raising the sustainability certification threshold from 7.5 MW to 20 MW, easing pressure on small operators.
• Removing new EMS obligations under the Industrial Emissions Directive, which add costs without proven benefits.

A consistent and workable framework

Simplification should align interlinked legislation (EUDR, REDIII, IED, and Carbon Removal Framework) to create a regulatory environment that is proportionate, practical, and supportive of EU competitiveness and climate goals.