Bioenergy Europe’s contribution to the Biotech Act II Call for Evidence
Supporting sustainable biomass value chains in Europe’s bioeconomy.
Bioenergy Europe’s feedback to the European Commission’s Call for Evidence on the Biotech Act II welcomes the initiative as an opportunity to strengthen Europe’s bioeconomy, industrial competitiveness and sustainable bio-based value chains. The contribution sets out Bioenergy Europe’s priorities for an effective framework: a technology-neutral approach, reliance on existing RED III sustainability and verification rules, and no parallel reporting systems.
The feedback also calls for a pragmatic approach to biomass use, avoiding rigid hierarchies that ignore regional realities, feedstock diversity and market conditions. It stresses that new bio-based markets should complement existing sustainable biomass value chains, which already provide the logistics, certification and investment basis needed to scale Europe’s bioeconomy.
Bioenergy Europe welcomes the European Commission’s ambition to strengthen Europe’s bioeconomy and industrial competitiveness through the Biotech Act II.
The initiative should create harmonised framework conditions for sustainable bio-based value chains, support investment certainty and accelerate the deployment of bio-based solutions that contribute to decarbonisation, circularity and European resilience.
To achieve this, the Biotech Act II should take an inclusive and technology-neutral approach to biomanufacturing. It should recognise the broad range of sustainable biomass conversion pathways, including biological, mechanical, chemical and thermochemical processes.
The Act should also help reduce regulatory fragmentation across Member States by improving harmonisation, regulatory predictability and market access for bio-based value chains. At the same time, it must avoid unnecessary regulatory duplication and recognise the role of established biomass value chains in mobilising sustainable feedstocks across the wider bioeconomy.
Bioenergy Europe calls on the European Commission to consider three key priorities:
Sustainability and verification should be based on existing EU frameworks
For biomass feedstocks, sustainability requirements linked to bio-based content, sourcing or market incentives should build on the existing sustainability and verification standards set out in the Renewable Energy Directive, particularly Articles 29 and 30.
The RED III framework already covers biomass sourcing, biodiversity protection, land-use safeguards, forest regeneration, carbon stocks, greenhouse gas performance and traceability. Creating parallel sustainability systems or additional reporting frameworks would duplicate existing obligations and add unnecessary complexity.
A pragmatic approach to biomass use and cascading is needed
Bioenergy Europe supports the efficient use of biomass throughout the bioeconomy, including reuse and recycling where technically, environmentally and economically viable.
However, biomass is not a homogeneous resource. Feedstocks vary in quality, regional availability, logistics, sustainability characteristics and end uses. Policy frameworks should therefore avoid rigid hierarchies that overlook local circumstances or market realities.
Bioenergy remains a significant contributor to the EU’s energy transition and will continue to play an important role alongside emerging bio-based applications and carbon removal strategies, including BECCS.
Existing biomass supply chains should support wider bioeconomy deployment
Sustainable biomass value chains already support feedstock mobilisation, certification, logistics and market access across Europe. These supply chains are essential for making biomass resources available for renewable energy, bio-based materials and other applications.
Scaling up bio-based pathways requires innovation, but also investment certainty, stable demand and robust supply chains. Policies that weaken existing sustainable biomass markets would risk reducing feedstock mobilisation and undermining the value chains needed for the wider bioeconomy to grow.
The development of new bio-based markets should therefore complement existing sustainable biomass value chains rather than weaken them.
