Bioenergy Europe’s answer to the Public Consultation on Taxonomy
Bioenergy Europe’s answer to the Public Consultation on Taxonomy
The Taxonomy should aim to integrate, not duplicate or diverge from, existing legislation and should not increase administrative burden in an already complex and shifting policy landscape. The EU Taxonomy should encourage, not restrict, private investments in renewable energy solutions such as sustainable bioenergy and BECCS. If access to private finance is constrained, the underlying need for these projects does not disappear; the cost simply shifts to taxpayers through increased public financing.
Brussels, 5 December 2025 – Bioenergy Europe welcomes the opportunity to contribute to the simplification of the Taxonomy technical screening criteria. Sustainable bioenergy plays a key role in the overall bioeconomy by valorising underutilised feedstock along the value chain and supplying reliable, around-the-clock energy. It already provides almost 13% of the EU’s energy consumption, making it the largest renewable energy source in the Union. Commission modelling shows that bioenergy use must increase by around 69–80% by 2050 for the EU to reach climate neutrality. No credible pathway achieves the 2050 target without an expanded contribution from sustainable biomass across power, heat, industrial processes, advanced fuels and permanent carbon removals such as bioenergy with carbon capture and storage
(BECCS).
Our key asks
- Need for stability and alignment with RED sustainability criteria
The Taxonomy should retain the sustainability requirements already defined in Article 29 of RED and refrain from introducing additional or parallel rules.
- The description of bioenergy activities (4.8., 4.20., 4.24.) should be revised to more clearly reflect the purpose of the Taxonomy.
The term “exclusively” used in the descriptions causes interpretative challenges among operators and does not take into account multi-fuel boilers, co-incineration plants, or, if interpreted strictly, even start-up and support fuels.
- Greenhouse gas emissions savings criteria
Proposing higher GHG savings thresholds for bioenergy in the Taxonomy, without a methodological basis in RED and without a clear, evidence-based rationale for specific values, would create an inconsistent system
for the same pathways.
- Recognition of supply-chain emissions for fuel-based renewables
Applying uniform kg/CO2e limits across technologies, or tightening thresholds without acknowledging these inherent characteristics, would disproportionately penalise bioenergy simply because it is fuel-based.
- System value and hard-to-decarbonise sectors
Biomass is indispensable in hard-to-decarbonise sectors. Tightening and differentiating GHG savings criteria in the Taxonomy for these pathways could restrict private capital from flowing into critical transition sectors, despite their centrality to EU climate objectives.
- Cascading principle and industrial grade roundwood
The Taxonomy should not attempt to incorporate or reinterpret RED III’s new provisions on the cascading principle and subsidy restrictions for industrial grade roundwood.
