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Bioenergia ry - Bioenergy Association of Finland

BEry

Bioenergia ry is the Finnish association representing the entire bioenergy sector and circular bioeconomy.

Lobbying Activity

Finnish bioenergy group urges alignment with existing renewable rules

5 Dec 2025
Topic — The Commission is reviewing technical screening criteria for the EU Taxonomy environmental act.
Message — The association demands that Taxonomy criteria remain fully aligned with existing renewable legislation. They oppose higher emission thresholds and new rules restricting wood use at project-level.12
Why — This would lower administrative burdens and protect the viability of existing capital-intensive projects.34
Impact — Taxpayers may face higher costs if private financing constraints force increased public funding.5
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Finnish Bioenergy Association urges recognition of bioenergy in circular economy plans

6 Nov 2025
Topic — EU Circular Economy Act aims to enhance competitiveness and promote sustainable production models.
Message — The association requests that sustainable bioenergy be promoted and recognized in EU bio- and circular economy plans. They support minimum bio-based content targets for selected products like biochar, but oppose blanket targets that could reduce quality or restrict innovation. They reject regulatory biomass use hierarchies while accepting the cascading use principle without rigid regulation.12345
Why — This would protect their members' market flexibility and prevent regulatory constraints on biomass use.67
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Meeting with Elsi Katainen (Member of the European Parliament)

6 Nov 2025 · Renewable energy and upcoming legislation

Finnish Bioenergy Urges EU to Include Heating Security in Energy Framework

13 Oct 2025
Topic — Revision of EU energy security framework addressing gaps from recent energy crisis.
Message — The association requests EU energy security framework include heating systems and transport, not only electricity and gas. They emphasize bioenergy's role providing dispatchable, storable renewable heat and supporting district heating networks.123
Why — This would secure their members' market position in heating against rapid electrification.45
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Finnish Bioenergy Association calls for lifting ICE ban, embracing carbon-neutral fuels

10 Oct 2025
Topic — EU regulation setting CO2 emission performance standards for new cars and vans.
Message — The organization requests removing the categorical ban on internal combustion engines and allowing their use post-2035. They want carbon-neutral fuels fully included in the regulation through a new vehicle category for vehicles running exclusively on such fuels, covering both e-fuels and renewable fuels.123
Why — This would expand markets for their biofuel products and bioenergy sector interests.45
Impact — Electric vehicle manufacturers lose regulatory advantage pushing electrification of transport.67
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Finnish Bioenergy Industry Urges Technology-Neutral Approach to EU Heat Strategy

9 Oct 2025
Topic — EU strategy to accelerate decarbonisation of heating and cooling across Europe.
Message — The association requests technology neutrality as a guiding principle and stability in renewable energy rules until 2030. They want recognition of district heating's role and blended finance mechanisms for clean heating solutions.123
Why — This would protect their sector from restrictive policies and secure investment certainty.45
Impact — Environmental groups lose targeted policies to phase out specific harmful biomass sources.6
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Finnish Bioenergy Association Opposes Biochar Feedstock Restrictions in EU Carbon Removal Rules

22 Sept 2025
Topic — EU methodologies for certifying permanent carbon removal activities including BioCCS and biochar production.
Message — The association requests removal of restrictions limiting biochar projects to waste feedstocks when biochar is the primary product. They argue such restrictions lack scientific justification and would marginalize biochar production. They also call for alignment with the Renewable Energy Directive and clarification that cascading principles apply only when subsidies are granted for energy production.1234
Why — This would expand eligible biomass sources for their biochar members and reduce regulatory burdens.56
Impact — Environmental groups lose stricter safeguards against diverting wood from material uses to carbon removal.7
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Finnish Bioenergy Sector Backs 2040 Climate Target with Flexibility

15 Sept 2025
Topic — Amendment to European Climate Law to establish EU's 2040 climate target toward 2050 neutrality.
Message — The association supports the Commission's proposal allowing limited use of high-quality international emission units for the 2040 target. They want permanent carbon removal solutions included in the emissions trading system and prefer climate policy to focus primarily on emissions rather than technology-specific rules.123
Why — This would reduce climate policy costs and allow leveraging of private capital for carbon removal.45
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Finnish Bioenergy Association Urges Priority for Biogenic CO2 Infrastructure

11 Sept 2025
Topic — EU legislative initiative on competitive CO2 markets and transportation infrastructure.
Message — The association requests explicit regulatory recognition of biogenic CO2, targeted transport infrastructure development, and funding models that prioritise early connection of biogenic sources. They emphasise that coordinated infrastructure development and market design valuing permanent removals are essential.123
Why — This would unlock their biogenic CO2 streams for the emerging market and reduce infrastructure costs.45
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Bioenergy Association urges inclusion of alternative fuels in corporate fleets

8 Sept 2025
Topic — A consultation on setting minimum requirements for zero-emission vehicles in corporate fleets.
Message — The association urges expanding the initiative to include alternative fuels and carbon-neutral fuels. This ensures a technology-neutral approach while providing more options for European companies.12
Why — This would protect the market relevance and competitive technological autonomy of bioenergy.3
Impact — Pure zero-emission vehicle manufacturers lose market exclusivity within corporate fleet requirements.4
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Finnish Bioenergy Sector Warns CBAM Extension Threatens EU Exports

26 Aug 2025
Topic — Extending carbon border mechanism to downstream products and anti-circumvention measures.
Message — The association requests that CBAM not be extended to downstream products and that implementation be simplified. They argue emission data from supply chains is unavailable and non-EU suppliers refuse to provide it. They propose allowing default values without penalties and developing a global emissions database.123
Why — This would reduce administrative burden and protect their strong global market share in bioenergy technologies.45
Impact — EU climate policy loses effectiveness as exemptions weaken carbon pricing mechanisms.6
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Bioenergy Association of Finland urges including carbon removals in ETS

8 Jul 2025
Topic — Review of the EU Emissions Trading System and Market Stability Reserve rules.
Message — The association supports integrating permanent carbon removal units, such as BECCS and biochar, into the EU ETS. They recommend a phased approach with volume caps to avoid undermining direct emission reduction incentives.12
Why — Integration would provide the sector with private capital and a liquid market.3
Impact — Temporary carbon removal providers are excluded from the lucrative ETS compliance market.4
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Bioenergia ry urges full integration of bioenergy in EU strategy

23 Jun 2025
Topic — This consultation seeks solutions for a circular, climate-neutral, and competitive European bioeconomy.
Message — The association demands bioenergy becomes a key pillar of the upcoming Strategy. They call for prioritising biogenic carbon dioxide over fossil alternatives in industrial processes. The Strategy should respect regional differences in infrastructure and energy needs.123
Why — Targeted funding and mobilisation programmes would create growth for local energy businesses.45
Impact — Fossil fuel industries lose as prioritising biogenic carbon dioxide supports a de-fossilised economy.6
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Response to Land use, land use change and forestry - flexibility mechanism related to impacts from natural disturbances

13 Jun 2025

Bioenergia ry the Bioenergy Association of Finland thanks the Commission for the opportunity to provide comments to the draft implementing regulation on LULUCF flexibility mechanism for impacts of natural disturbances. According to the LULUCF regulation, Member States shall be entitled to compensate net emissions or net removals, or both, up to the amount unused by other Member States of the full amount of compensation for the period from 2021 to 2030, provided that those Member States have submitted evidence to the Commission concerning either: the long-term impact of climate change resulting in excess emissions or diminishing sinks that are beyond their control; or the effects of an exceptionally high proportion of organic soils in their managed land area, compared to the Union average, resulting in excess emissions, provided that those effects are attributable to land management practices that occurred before the entry into force of Decision No 529/2013/EU; Paragraphs 13b.8 and 13b.9 specify requirements for both cases in the LULUCF regulation. We note that 13b.9 refers to the use of comparable and reliable geographically explicit data and on the best scientific evidence available, whereas the draft says that the relevant Member States would need to identify areas in a geographically explicit manner. Also, the LULUCF regulation requires Member States to provide a description of policy measures currently implemented that minimise the negative impacts of legacy effects on managed organic soils. The draft implementing regulation, however, requires a detailed description of the efforts to reverse the trend of excess emissions generated in the areas identified. There is a slight difference in these expressions, which may have significant consequences in terms of administrative burden. Many Member States, including Finland, will require flexibility mechanisms to achieve the LULUCF targets, while they try to improve competitiveness at the same time. In the spirit of improving the Unions competitiveness and reducing administrative burden in the Union, we would recommend harmonising the implementing regulation with the agreed LULUCF regulation and making the use of the flexibility mechanism as simple and straight-forward as possible.
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Bioenergy Association of Finland seeks wood and waste exemptions

13 May 2025
Topic — Amending the list of commodities covered by the EU Deforestation Regulation.
Message — Bioenergia ry proposes excluding wood from permanent crops and clarifying waste exclusions. They aim to avoid unnecessary administrative burden and simplify the regulation.123
Why — Reduced administrative burdens and simpler rules would lower costs for bioenergy operators.45
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Response to List of net-zero technology final products and their main specific components

20 Feb 2025

Bioenergia ry - The Bioenergy Association of Finland welcomes the opportunity to provide feedback on the draft Delegated Act amending Regulation (EU) 2024/1735 (Net-Zero Industry Act) concerning the list of net-zero technology final products and their main specific components. Please find attached our contribution.
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Meeting with Aura Salla (Member of the European Parliament)

19 Nov 2024 · The upcoming term

Finnish bioenergy group demands delay in fuel traceability rules

7 Nov 2024
Topic — Expansion of the Union database to track raw fuel material production.
Message — The association demands postponing the regulation's application until January 2026. They also seek exemptions for small biogas and biomethane producers.12
Why — A delay would prevent excessive administrative costs for smaller energy producers.3
Impact — Regulators and environmental groups lose tools for credible verification of fuel sustainability.4
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Finnish Bioenergy Association urges predictable rules for low-carbon fuels

25 Oct 2024
Topic — This consultation defines the methodology for calculating greenhouse gas emission savings for low-carbon fuels.
Message — The association requests flexible rules for producing different hydrogen types in one facility. They also urge the Commission to review if fuel derivatives can realistically meet emission thresholds.12
Why — Stable production rules will enable companies to finalize feasibility studies and advance investments.34
Impact — High-emission fossil hydrogen producers will face higher costs due to mandatory unverified markups.56
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Meeting with Elsi Katainen (Member of the European Parliament)

1 Oct 2024 · Energia- ja ilmastopolitiikka, bioenergia-ala

Finnish Bioenergy Association urges biochar recognition in storage rules

16 Jul 2024
Topic — New EU rules defining when captured emissions are permanently stored in products.
Message — The group calls for including biochar in storage rules to ensure regulatory coherence. They argue biogenic carbon storage should be incentivized as removal instead of an exemption.12
Why — This would create new revenue streams and ensure long-term certainty for bioenergy investors.34
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Finnish bioenergy group urges fairer LULUCF targets and peat accounting

11 Jul 2024
Topic — This consultation evaluates the effectiveness of EU rules for land use, land-use change, and forestry.
Message — The association calls for a revision of unrealistic targets and unfair distribution among Member States. They request reporting rules that recognize carbon storage in peat and prevent double reporting.123
Why — Revised accounting would lower reported emissions and costs for the Finnish peat industry.4
Impact — Environmental goals are at risk if reporting rules allow some countries to increase emissions.5
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Response to Environmental Implementation Review 2025

5 Jul 2024

As the recently adopted Strategic Agenda 2024-2029 clearly shows, the EU faces multiple challenges in a very unstable geopolitical situation. We have serious concerns regarding the EUs security and competitiveness in addition to the well-known environmental challenges, which are also growing worse. In this context, Bioenergia ry - the Bioenergy Association of Finland would like to highlight, in particular, two major issues for the 2025 EIR. First, the amount of new environmental legislation in the energy sector significantly increased in the 2019-2024 period. Implementation of all this legislation (within the foreseen deadlines) has already proven to be challenging and not only in Finland, but in many other Member States and in the Commission, too. Unclear legislation and missing guidance for implementation has increased confusion and uncertainty in many businesses. The new legislation will in many cases also increase administrative burden also in small companies. All this will have negative impacts on investment, competitiveness and employment. At the same time, the amount of legislation and the length and detail of this legislation does not always imply optimal environmental outcomes as a result. We would therefore hope that in its next EIR, while maintaining its environmental ambition the EU would seriously pay attention to - simplification of legislation and avoidance of unnecessary micromanagement - true neutrality regarding the use of different technologies to solve the problem at hand - cumulative impact of all adopted legislation in companies - realistic timelines for implementation of legislation Second, investment is key for Europes socioeconomic future, and also to solve many of our environmental problems. Licensing and permitting has widely been acknowledged as a bottleneck for investment and it has already been addressed in the 2019-2024 period. We fully support these and further measures to streamline licensing and permitting processes to make the EU a lucrative location for businesses to invest in environmentally friendly technologies. In Finland, the Confederation of Finnish Industries hosts a website (see below) of all green investments under preparation. The amount of projects and the potential total investment ( 269 billion) is formidable. While all of the projects are unlikely to move forward, a wise EU environmental policy can support realisation of a maximal number and a well-balanced portfolio of these transformative projects and help to minimise negative impacts. see: https://ek.fi/en/green-investments-in-finland/
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Response to Assessment of the energy efficiency public funding support at Union and national level

26 Feb 2024

The planned report will provide an overview of the existing financing landscape in the European Union, assess its effectiveness and efficiency, its capacity to leverage private financing and ultimately to reach the EU energy efficiency targets. It aims to clarify the panorama of public funding for energy efficiency in Europe, and intends to highlight good practices with a potential for replication. Bioenergia ry the Bioenergy Association of Finland - welcomes such a report as a useful tool to inform EU-level and national policies in particular, in highlighting best practices. Our key messages: 1. Predictable policy environment is important. Retroactive changes to adopted policies deteriorate the investment environment. 2. The call for evidence states that there is currently no dedicated funding targeting exclusively energy efficiency in any of the large EU funding programmes. According to the call, Energy efficiency is therefore in competition with other priority sectors. We believe such an approach is misleading and should be reconsidered. Energy efficiency greatly contributes to achievement of goals e.g. in the EU ETS and Effort Sharing Sectors. On the other hand, an ambitious emissions reduction target can similarly promote also energy efficiency. 3. In the 2030s the EU climate and energy policies should clearly focus on greenhouse gas emissions and not on fragmented, separate policies like renewable energy, energy efficiency, sectoral or technological policies. 4. The Bioenergy Association of Finland emphasizes the importance of technology-neutral approach in EU policy making. Creating lists of the proper technologies or solutions to reach the mid- to long-term climate goals years ahead is by no means the optimal method. There is no certainty regarding the best solutions in the years to come and these solutions should be determined by markets and technological development and not by political decisions. R&D support is, however, key for all sustainable technologies. 5. In promotion of energy efficiency, operating models combining well-functioning voluntary agreements with mobilisation of private finance, via e.g. specialised investment funds, for projects with slightly longer payback times are promising. 6. Bio-CHP plants operate with high energy efficiency, are important for EUs energy security (95 % of energy biomass is domestic) and are fully compatible with a carbon-negative future, when accompanied with CCUS-technologies. District heating networks can serve as future-proof platforms for a comprehensive energy transition, and the Nordic countries can among others provide a lot of interesting recent or on-going examples here ranging from industrial heat pumps to energy storage, to waste heat utilization, to hydrogen economy and to bio-CCUS technologies. Energy efficiency policies should recognise the value of CHP and district heating networks and not unnecessarily deteriorate their operating environment. 7. Modernisation of the current stock of biomass heating appliances with new appliances would bring great energy efficiency benefits - and in conjunction with decreasing air pollutant emissions. Very often the owners are elderly or low income households, and public intervention could ease financing and lower the threshold for investment.
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Finnish Bioenergy Association labels forest monitoring proposal "unsubstantiated"

7 Feb 2024
Topic — The EU initiative aims to establish a unified framework for forest observation and management.
Message — The association opposes redundant regulations and warns that remote sensing cannot replace accurate field inventories. They request that data on bioenergy use be aggregated to avoid excessive detail.123
Why — Aggregating data would reduce the technical and administrative burden on bioenergy companies.45
Impact — Regulators lose the ability to track wood use at a detailed user level.6
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Response to Managing EU climate risks

14 Jan 2024

Bioenergia ry the Bioenergy Association of Finland supports the Commission initiative on EU climate risk assessment and developing EU-wide management of the climate risks. The level of warming was 1.45 ± 0.12 °C above pre-industrial levels (1850-1900) in 2023 (WMO 2024). Based on the recent assessments it is quite clear the world is on a path, where we will see significantly higher temperatures during the next few decades. In the most optimistic estimates, where all announced climate action is fully implemented we could be achieving 1.8°C warming or even less by 2100 but likely after a significant overshoot. Accordingly, we find the envisaged approach quite promising. It is very useful to collect, produce and review information on climate risks in Europe, and to publish and communicate this. Just as planned, the main objective after the climate risk assessment should be to identify where coordinated action at the EU level is required or brings benefits vs. action in individual Member States. According to the call for evidence, the impacts on economic activity, employment, single market, territorial cohesion, environment, energy, public health, food security, distributional implications and trade are examples of areas that should be considered. We agree. Warming may have impacts on energy security, which could be usefully analysed at the European level. The impact of warming on European forests may take many forms, but it is already evident that warming is a significant challenge for the prevention of biodiversity loss in Member States. Also, warming may impact on land-based greenhouse gas emissions, the relative importance of which in EU climate policy is growing, as the EU energy system is quickly getting rid of fossil fuels. A better understanding of climate risks must be fully incorporated in EU efforts to fight against climate change and biodiversity loss. Policies need to be planned in a way that set meaningful targets for individual countries, regions and sectors taking also into account change that cannot be avoided any longer in the short term. It would also be useful to assess the impacts the additional warming might have on migration needs towards the EU. Migration clearly requires coordinated action at the EU level. Source: Climate Action Tracker, 2023, https://climateactiontracker.org/press/release-projected-warming-almost-unchanged-for-two-years-as-governments-push-false-solutions-over-climate-action/ WMO, 2024, https://wmo.int/media/news/wmo-confirms-2023-smashes-global-temperature-record
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Meeting with Ville Niinistö (Member of the European Parliament) and Paikallisvoima ry and Energiakaupungit ry

12 Jan 2024 · Current EU policies, e.g. energy policy

Meeting with Nils Torvalds (Member of the European Parliament) and Paikallisvoima ry and Energiakaupungit ry

12 Jan 2024 · EU elections

Finnish bioenergy sector rejects merging heat pump and boiler labels

21 Dec 2023
Topic — The initiative reviews energy efficiency labels and rescaling requirements for solid fuel boilers.
Message — The association urges maintaining the Biomass Label Factor and separate labels for different technologies. They argue that excessive regulations make modern boilers too expensive and hinder air quality improvements.12
Why — These measures would protect the market position of biomass boilers against competing technologies.3
Impact — Air quality suffers when strict rules prevent the replacement of old, polluting systems.4
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Finnish Bioenergy Association urges flexibility in EU soil monitoring

3 Nov 2023
Topic — This consultation concerns new EU legislation for monitoring, managing, and restoring healthy soils.
Message — The association calls for a risk-based, cost-conscious approach and a 10-year monitoring interval instead of five. They reject the "one out-all out" principle and demand that data collection not burden individual landowners.123
Why — Using existing data and longer intervals would reduce bureaucracy and high measurement costs.4
Impact — Environmental groups lose as higher damage thresholds and infrequent checks may hide degradation.56
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Bioenergy Association of Finland urges prioritization of biogenic carbon removals

31 Aug 2023
Topic — This consultation evaluates the role of carbon capture technologies in decarbonizing the European economy.
Message — The association requests a policy hierarchy prioritizing biogenic carbon removal over fossil fuel capture. They demand financial rewards for negative emissions and a unified EU-wide market for CO2 transport.123
Why — Specific incentives for biogenic storage would allow Finnish bioenergy operators to monetize their carbon emissions.4
Impact — Newer carbon removal technologies could lose financial support if the EU prioritizes the most mature solutions.5
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Finnish Bioenergy Association Calls for Less Bureaucracy in Green Claims

19 Jul 2023
Topic — EU proposal requiring companies to verify environmental claims using standardized footprinting methods.
Message — The group wants to minimize bureaucracy and align rules with the RED3 Directive. They advocate for simple labels to prevent consumers from ignoring complex info.123
Why — This would reduce administrative costs and protect international competitiveness for bioenergy firms.4
Impact — Regulatory bodies seeking granular transparency might lose access to comprehensive data.5
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Finnish bioenergy sector calls for strategic status in EU act

22 Jun 2023
Topic — The consultation explores ways to boost the manufacturing of clean energy technologies within Europe.
Message — The association urges including solid bioenergy as a strategic technology to prevent industry relocation. They also advocate prioritizing incentives for biogenic carbon removal over fossil fuel capture. Finally, they propose lowering readiness thresholds to speed up deployment of new solutions.123
Why — Strategic status would ensure Finnish bioenergy providers receive critical support and faster permitting.45
Impact — Fossil fuel developers would face relatively weaker incentives than biogenic carbon storage projects.67
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Finnish biofuel industry urges life-cycle emissions approach for heavy vehicles

19 May 2023
Topic — EU proposal to strengthen CO₂ emission standards for new heavy-duty vehicles.
Message — The organization requests a shift from tank-to-wheel to well-to-wheel emissions accounting that distinguishes biogenic from fossil CO₂. They want the heaviest vehicles, agricultural machinery, and forestry equipment exempted from the regulation.12
Why — This would allow their biofuels to compete by crediting emission reductions from renewable content.34
Impact — Climate advocates lose stricter tailpipe standards that drive faster electrification of transport.5
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Bioenergy Association warns against favoring reuse over recyclable packaging

24 Apr 2023
Topic — The Commission is reviewing requirements to reduce packaging waste and increase recycling.
Message — Reuse and recycling should be treated as complementary solutions. The association warns that favoring reusable packaging risks promoting fossil-based materials over bio-based alternatives. They request flexibility for Member States to evaluate overall environmental impacts.123
Why — This protects the supply of forestry residues used for carbon-negative energy systems.4
Impact — Fossil-based material cycles lose the advantage they might gain from strict reuse mandates.5
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Finnish bioenergy group urges EU to include biochar as permanent storage

23 Mar 2023
Topic — This consultation covers a new regulatory framework for certifying and monitoring sustainable carbon removals.
Message — The association requests that biochar be explicitly classified as a permanent storage method alongside industrial technologies. They also advocate for aligning sustainability criteria with existing bioenergy laws to avoid conflicting requirements. Furthermore, they argue that technical methodologies should not be used to settle political questions.123
Why — These changes would reduce administrative burdens and ensure bioenergy operators can access carbon markets.45
Impact — Environmental groups may lose out as the industry pushes for less stringent sustainability standards.6
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Bioenergy Association of Finland urges support for cover crops

2 Jan 2023
Topic — The consultation updates the list of sustainable feedstocks for biofuel production.
Message — The group wants intermediate crops in list A to improve business cases. They request simpler definitions and a higher cap for list B feedstocks.123
Why — This would increase investment predictability and expand market access for their products.45
Impact — Environmental monitoring may be weakened by simplified definitions and local assessment.6
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Response to Review of cogeneration reference values

29 Dec 2022

As has been seen since 2021 the reliance on fossil fuels has proved to pose a dangerous shackle for European societies. Great majority of global natural gas reserves originate from non-democratic countries. This reliance must be cut starting with new plants and in the electricity production where abundance of better options is available. Therefore, neither fossil natural gas nor other fossil fuels should be eligible in regular use in newly commissioned plants from 2024 (Annex I-II). Instead, renewable fuels, synthetic gases, green hydrogen, and waste-based fuels should be possible from 2024. The tables on Annex I - II should be changed accordingly. The Bioenergy Association of Finland emphasises that non-fossil gases, such as biomethane, synthetic gases and gases based on thermal gasification should be favoured and their use in old and new plants promoted in Union legislation. Additionally, we note that on category S6 (Municipal and industrial waste), the efficiency value 25 % is to remain the same as it has been for a very long time. This efficiency value does not reflect in any way the technological development or BAT, nor actual investments made in several countries. Therefore, we propose the efficiency value to be raised to 28-30 %.
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Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

The PPP requires polluters to pay for the pollution they cause. The Bioenergy Association of Finland believes that in the context of climate change mitigation more attention should be paid to the definition of "Pollution" in the PPP. For example, even the most recent provisional agreement on the LULUCF regulation suggests that a declining carbon sink is - in the context of the PPP - fully comparable to a GHG emission. This leads to a current situation, where some Member States are forced to maintain a high level of carbon sinks and even increase them regardless of their industrial structure or economic forecasts, whereas others are allowed to even generate emissions from the LULUCF sector. We do not consider this interpretation of the PPP sound nor fair. We strongly believe that true application of the PPP in climate change mitigation would focus more on "stick" for GHG emissions from fossil fuels and elsewhere, whereas the simultaneous need for higher carbon dioxide removals in the EU should be addressed more with different kinds of "carrots", such as those enabled by the recently proposed Carbon Removal Certification Framework from the Commission. It is useful that the fitness check is based on a set of criteria. Criteria, such as effectiveness, coherence and efficiency, are justified. However, "relevance" and "EU added value" are questionable criteria, since the PPP is a key principle underlying EU environment legislation and policies, as set out in Article 191(2) of the Consolidated Version of the Treaty on the Functioning of the European Union. The PPP as such is based on an interpretation about what is fair. Therefore it seems illogical that fairness would be a subcriterion (under "efficiency") to evaluate PPP. It is also very unclear what the meaning of "Whether the PPP is able to respond to new or emerging environmental issues and changes in technology." is.
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Bioenergy Association Urges Biomass Inclusion in Go-To Areas

26 Jul 2022
Topic — This consultation addresses barriers to renewable energy project permitting and power purchase agreement facilitation.
Message — The group demands that sustainable biomass be included in the new renewable go-to areas. They want the policy to support heating and rural areas alongside wind and solar.12
Why — This would help European bioenergy manufacturers maintain their market position and technological edge.3
Impact — Solar and wind industries would lose their exclusive advantage in streamlined permit-granting zones.4
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Bioenergy Association of Finland urges broader CO2 source rules

17 Jun 2022
Topic — Setting the methodology for greenhouse gas savings in recycled and renewable fuels.
Message — The association demands including carbon from waste incineration and annual updates for electricity grid emissions. They seek a full lifecycle approach to prevent market distortions for hydrogen production.123
Why — Including waste-derived carbon would facilitate timely investments and ensure accurate emission accounting.45
Impact — European member states could lose investment capital to external hydrogen producers under current rules.6
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Bioenergy Association urges ambitious EU carbon removal targets

2 May 2022
Topic — The European Commission is proposing a regulatory framework for certifying carbon removals.
Message — Bioenergia ry calls for a certification framework by 2026 with significantly higher targets. The system must remain technology neutral to support both biochar and industrial carbon capture.123
Why — This framework would generate revenue to support and upscale the bioenergy sector's technology.4
Impact — Producers of short-term carbon products lose out as the association demands stricter permanence rules.5
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Finnish bioenergy association urges faster permitting and less micromanagement

12 Apr 2022
Topic — EU guidance for member states on streamlining renewable energy permitting and administrative processes.
Message — The group advocates for better staffing of authorities to significantly speed up decisions. They want land use planning and permitting processes linked to avoid overlapping work.12
Why — Faster procedures would reduce regulatory uncertainty and lower the industry's administrative costs.3
Impact — Local stakeholders could see their influence diminished by new models to prioritize interests.4
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Finnish Bioenergy Group Advocates for Hybrid Solar-Bioenergy Plants

12 Apr 2022
Topic — The EU Solar Energy Strategy aims to accelerate deployment and improve energy resilience.
Message — Integrate solar energy with bioenergy plants and repurpose cut-over peatlands for panels. They advocate for sustainable land use alongside animal grazing and biodiversity targets.123
Why — Member organizations and landowners could generate additional income from low-productivity property.4
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

The Bioenergy Association of Finland sees energy efficiency as paramount for the resilience of the European energy system. Building sector is very versatile spanning from urban public buildings to rural residential buildings. Therefore, it is crucial to find efficiency solutions to serve all building types. It is to be noted that inclusion of renewable and waste-based district heating and cooling is seen as one option for zero energy building. This is an important choice as district heating should be seen as infrastructure that in higher density areas serves as energy network or platform for many energy carriers. The proposal for revision builds on elements that mainly can be supported. We for instance welcome the carbon emissions life cycle approach of the whole building and the de-facto ban on investments for new fossil fuel-based boilers. However, we would like to raise one issue: Primary energy factor. Primary energy factors of different energy forms are also dependent on the geographic location and the national energy systems. It is necessary to leave room for national competence on the definition of primary energy factors. The Commission can produce guidance on the calculation of primary energy factors for consistency, though.
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Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

15 Mar 2022

Soil Strategy and further development towards a Soil Law may pose high challenges for the Member States with high proportion of organic soils and particularly peatlands and their wise use. In its first chapters the document states many general needs and reasons for a common Soil Strategy. However, justification and the close synergies, even overlaps with other EU policies should be better described. Subsidiarity is a prerequisite in getting approval of the citizens in many Member States, where soil characteristics and also their utilization differs to great extent. There are more than ten other EU strategies, plans, initiatives and existing policies, particularly on pollution and emission in place touching also soils. The awareness and actions for soil are already ongoing in the Member States as stated also in the text. Therefore one has to ask critically the role of the Soil Strategy in general. An objective “Significant areas of degraded and carbon-rich ecosystems, including soils, are restored” can be interpreted in different ways, especially if we are to shift towards restoring all carbon-rich ecosystems. With high pressure on the protection and restoration of peatlands in many Member States we are suffering from being in a climatic zone where precipitation exceeds evaporation and peat is accumulating and peatlands are forming. Even if the Strategy would not yet be legally binding such a requirement can not be applied without setting some limits by e.g. percentages protected or restored etc.. Soil can ”act as a carbon reservoir”, but also sequester carbon, and thus allowing wise use of the soil carbon stocks in a resource efficient and net positive manner. The definition of peatlands does not meet the current definition - at least 30 cm of peat - and distinction between organic soil and peatland (bog) disappears “Emissions from cultivated organic soils have still not decreased significantly due to the continuation of harmful cropping practices. Yet restoring drained organic soils alone could significantly reduce CO2 emissions from land, which comes with numerous co-benefits, for nature, biodiversity and water protection .“ This chapter has obvious implications to peatlands. This comes also with collateral damages and unwanted side effects, if the need for drainage is not put into equation and a question how to substitute all the existing ecosystem services and benefits got fully answered. Restoration targets especially on peatlands should not hamper GHG reduction targets. Emissions can be reduced effectively and faster also by other land use patterns, practising paludiculture, afforestation where appropriate and in some cases also cultivation perennials or other crops. In the absence of criteria for the proportion of managed peatlands to be restored, the requirement to restore managed and drained peatlands may result in many disadvantages and to social challenges. The suggested "passport for excavated soil" is unnecessary and only adding to the bureaucracy. It would also be contradictory to the principle of subsidiarity quoted earlier. As EU is setting targets of Urban Greening and plans to achieve it, it is essential to know that without utilization of organic soils and peat that is unrealistic. Protection of water resources and targets to meet good status of groundwater and water courses are best taken care of in EU water regulation (WPD), and there is no need to extend this to Soil Law. Sustainable Soil Management (SSM) practices is best known and applied at grass-root level, locally, not told by European level. It would be up to the Member States to decide, if they spend their budget money on suggested "free" soil testing. It would be very hard to determine pan-european specifications for the test, because there are so different soils and aspects of soil usage i.e. how to interpret the results, what is the minimum "free test standard" etc. e.g for forest soils, garden soils, agricultural soils etc.
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Response to Act amending Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions

11 Jan 2022

The Bioenergy Association of Finland welcomes this initiative. There is a clear need for this amendment as the implementation on RED2 sustainability criteria is long overdue and this may have detrimental effects on the use of biomass in the ETS sector. Therefore, it is a matter of urgency that the proposed implementing regulation will be promptly adopted restoring legal certainty for users of biomass. We encourage the EC to prioritize work on this file, and communicate accordingly with relevant national regulatory authorities and market participants seeking guidance on the accounting of emissions from biomass within the EU ETS and the new legislative framework set by RED2. Lack of clarity in this regard currently undermines the competitiveness of biomass technologies and is contradictory to both the objectives of the Fit-for-55 package and the intention of the legislator who explicitly stated that sustainable biomass should retain emission factor zero within the proposed revision of the EU ETS Directive. We support and highlight the use of forest industry and forestry by-products and wood residues for energy production, as the usage of sustainable woody biomass can make a meaningful contribution to climate change mitigation. We acknowledge the concerns that an increased EU biomass demand could also have short term negative impact on carbon sink and biodiversity. Hence, a robust, harmonized and timely implementation of the new sustainability criteria by Member States and economic operators is crucial and these implementing rules are needed to facilitate functioning biomass markets. It must be highlighted that some Member states have acted on time and implemented the criteria in national laws and have thus been waiting for the EC to act for the past year. This applies to Finland, where the economic operators have anxiously been waiting for the EC to publish the guidance on examples of rules for the criteria and are still waiting, while the deadline for national implementation was on June 30th this year. The operators acted according to RED2 and national laws. It is very unsatisfactory that there is still a great unclarity whether the Commission is expecting MSs to update national schemes according to the implementing rules. This situation creates a real practical problem for both national administrations and stakeholders using biomass, which is absurd given the EU’s very high dependence on fossil fuels and the great emphasis to drive renewable energy. This is also harmful for the long-term investment environment in Europe. On the amending Implementing Regulation itself. We see no reason to bring up the national taxation schemes or cascading use and waste hierarchy in this implementing regulation. In fact, these do not even fall into the competence of the Commission on ETS MRR. Taxation is currently discussed in the context of the proposal of energy tax directive. The issue of cascading is likewise debated under RED3 proposal. Our view is that cascading as a principle should not be enforced through legislation. The Bioenergy Association of Finland supports the proposed amendment of art 38 of Monitoring and Reporting Implementing Regulation: ‘Member States may consider as fulfilled the sustainability and greenhouse gas emissions saving criteria referred to in that paragraph for biofuels, bioliquids, and biomass fuels used for combustion from 1 January 2022 to 31 December 2022.’ Moreover, derogation might be further strengthened by replacing 'may consider' with 'shall consider’. This wording would guarantee a robust, efficient, and harmonized implementation of the EU law within all Member States and decrease the threat of the fragmentation of the single market.
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Response to Review of Directive 2012/27/EU on energy efficiency

19 Nov 2021

Bioenergy Association of Finland supports the aims of the EU Green Deal and the objective of reducing net greenhouse gas emissions by 55 % by 2030. It is quite clear that achieving this objective also requires a significant improvement in energy efficiency around Europe. Nevertheless, it is disappointing that the Commission in the Fit-for-55 package did not focus on setting emission reduction targets for the EU ETS, ESR and LULUCF sectors and supporting that with e.g. financing tools. Instead, the Commission also decided to reopen – again - the RED and EED Directives. The Commission proposal is regrettably based on low trust in the ability of the market economy – or Member States - to find effective solutions, increasing EU influence within Member States’ national policies and EU-level micromanagement of several sectors. This leads to ineffective and overlapping policies, more bureaucracy and decreased flexibility at the Member State level. Particularly, we would raise the requirements set in Article 24 for production of efficient district heat and cooling as unnecessarily detailed in a situation, where the sector is already incentivised by the EU ETS, energy taxation and renewable energy directive in their investments. It is also important to note that heat producers operate in volatile markets for fuels, electricity and emission allowances (EUAs). Fixed assumptions and rules on the fuel mix are not compatible with real world circumstances. We also regret that the Commission has removed sorted waste from definitions for high efficient district heating and high efficiency cogeneration. Industrial wastes and waste gases are difficult to fully avoid in many industrial processes, even though the residual amounts can be significantly reduced. In the spirit of circular economy and resource-efficiency sorted waste and waste gases – having no other valuable uses – should be acknowledged as eligible fuels in high efficient district heating and high efficiency cogeneration. It is also unfortunate that the proposal includes flat sector-specific goals for annual efficiency improvements around Europe without attention to the regional circumstances and impacts.
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Response to Proposal for a Regulation on establishing a Climate Action Social Facility

18 Nov 2021

The Bioenergy Association of Finland considers the proposed Social Climate Fund problematic from many aspects and cannot support the proposal. Member States are responsible for social policy and protection of vulnerable households. The Social Climate Fund would directly intervene with the social sector of the Member States. There should be a proper discussion on the core EU principles of subsidiarity and legitimacy and any decisions taken before the EU takes such a concrete role on social policy and paying subsidies for individual households. We acknowledge the multitude of measures needed to achieve the Green Deal goals. However, social affairs and any direct compensations to households and individuals clearly belong to national policy and should be funded from national budgets. Social Climate Fund would require the revenues needed to pay back the loans of the Recovery and Resilience Facility. We consider the Social Climate Fund unjustified also because of the very recent Just Transition Mechanism and Just Transition Fund that are supposed to have similar goals (leave no one behind) - showing no evidence of results yet. It is obvious that Social Climate Fund cannot provide sufficient, fair and responsible economic support to all who may suffer from transition to low-carbon society. This was concluded also by the European Economic and Social Committee. Those who have done already more for the climate transition may have to subsidize those who have not. The proposed model of sharing the costs and benefits is unfair and may even hinder development towards climate neutrality in the Member States with high climate ambition.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

Bioenergy Association of Finland supports the target to reach EU climate neutrality in a socially, economically and ecologically sustainable way prior to 2050. The Association underlines the need to agree a balanced FF55 package that supports the -55 % emissions reduction goal rather than a wide set of other goals. The ETD proposal sets taxation levels based on environmental impacts as well as based on end use. We underline the need to further assess the ETD proposal and its impacts on energy security and environmental guidance on a national level. We strongly oppose the proposal to include a flat excise duty tax on biomass in heat production (plants above 5 MW). This would slow down the positive development in the transition away from fossil fuels in Europe. Biomass-based heat is an important renewable energy form and has more to offer as the largest climate gap in Europe is on the heating sector. Tax on biomass-based heating would send a totally wrong signal towards the companies of the sector and create further uncertainty. The Proposal builds on a structure where RFNBO or advanced and sustainable biofuels are within the scope but would be given tax reductions. Instead, we favour continued exclusion of RFNBO and advanced biofuels from ETD which gives member states more flexibility. Additionally we do not support including peat energy into the scope of ETD. Peat energy use is very limited in the EU concentrating in a few countries and its use is rapidly declining. In Finland, the ongoing collapse in the use of energy peat has already created a challenging case for just transition. The difficult position of companies, entrepreneurs and workers in the sector should not be further aggravated. In case peat is added the member states should be left with the option to deviate from general taxation levels. The revised ETD must better reflect the environmental impact of polluting energy products and remove subsidies for fossil fuels. It is therefore crucial that sustainable biomass fuels are exempted from the scope of the proposed legal act . One of the paramount challenges of the comprehensive reform of the carbon pricing system proposed within the Fit for 55 package is to design such reform in a socially acceptable way. The extension of the carbon pricing via the EU ETS system on fossil fuels used in the building sector and transport sector, combined with higher excise rates and phased-out subsidies and tax exemption for such fuels, will inevitably lift price levels. The impact of such changes will be mostly felt by vulnerable customers. Sustainable biomass fuels are the most affordable and common replacement of fossil fuels in the heating sectors. These solutions are cost-competitive, market-ready, and easy to scale up. As bioenergy is locally sourced, the development of its value chain facilitates the creation of local jobs and regional and rural development objectives. Therefore, to offset the prospective rise of prices in the heating sector, the use of sustainable bioenergy fuels should be promoted and incentivized. The purpose of the ETD is to minimize unfair competition on a common market. This is mainly a problem concerning fossil fuels. For bioenergy, there is scarce evidence that tax exemption or reductions have been used to distort competition on the market. On the contrary, measures undermining the competitiveness of such products will result in slowing down decarbonization pace in sectors that are already lagging behind in the process.
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Finnish bioenergy association rejects new biomass sustainability criteria

18 Nov 2021
Topic — The European Commission is revising the Renewable Energy Directive to meet 2030 climate goals.
Message — The association opposes retroactive sustainability measures and demands that forestry management remains under national control. They also call for technology-neutral targets to support negative emission technologies.123
Why — This would protect existing investments and prevent the premature closure of biomass energy plants.4
Impact — Environmental groups lose direct protections for biodiverse areas if they are managed via risk-based assessments.5
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Finnish bioenergy industry calls for biofuels recognition in vehicle emissions

8 Nov 2021
Topic — EU regulation strengthening CO2 emission standards for new cars and vans.
Message — The association urges the EU to move beyond tank-to-wheel emissions accounting to include well-to-tank performance and biogenic content. They want biofuels and power-to-x fuels recognized through a voluntary crediting mechanism for manufacturers.12
Why — This would expand market demand for their biofuels beyond hard-to-electrify sectors.34
Impact — Electric vehicle manufacturers lose regulatory advantage if biofuel vehicles count as low-emission.5
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

8 Nov 2021

The Bioenergy Association of Finland welcomes the Commission proposal to revise the Effort Sharing Decision (ESR) as part of the Fit-for-55 package. While the EU ETS is the most important single instrument the European Climate Law, the ESR has an important role in reducing greenhouse gas emissions in Europe, too. In the big picture, the emphasis of the Fit-for-55 package must be on reducing emissions and the use of fossil fuels. We believe the ambition level of the EU ETS could be even higher, while the ambition level for the ESR sectors could be respectively lower. Now the target (-61 % vs. 2005) for the EU ETS is increased with 10 percentage points compared to the BAU level, while the target for ESR is increased with almost as much: with 8 percentage points compared to the BAU level. The EU ETS sector has an efficient and liquid market system, where the market participants are typically companies, and emission reductions can be easily monetised. The ESR sector is under Member States’ responsibility and tends to have higher marginal emission reduction costs. Typically, there is no efficient market-based system to identify emission reductions in the ESR sector. Operators in the ESR sectors are e.g. municipalities, small companies, agricultural producers and private citizens. All in all, the situation already (with the current 30 % target) may lead to emission reduction costs of even 10,000 EUR/tCO2 in some specific policies in the ESR sector, while the price in the EU ETS is around 60 €/tCO2. We believe all Member states should participate in enhanced emissions reductions in the ESR sector. GDP/capita is used – as before – as the main method to allocate national targets. However, several adjustments to GDP / capita are also made. Some of these adjustments have a questionable basis, like limiting the highest targets to 50 % at maximum. For this reason, the burden sharing proposed is eventually far from treating equally prosperous Member States equally. All existing flexibility mechanisms should be available for Member States. In addition, flexibility mechanisms could be expanded as targets become more ambitious and thereby also challenging. Flexibility mechanisms could also be broader for Member States, which have the most ambitious targets.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

The Bioenergy Association of Finland welcomes the Commission proposal to revise the EU ETS as part of the Fit-for-55 package. The EU ETS is an important tool to implement the enhanced 2030 Climate Target. The EU ETS has proven its ability to reduce greenhouse gas emissions in the Union. It is technology-neutral and provides plenty of flexibility for its participants to fulfill the related obligations. The Bioenergy Association of Finland therefore strongly supports significantly strengthening the EU ETS and reviewing the rules for the Market Stability Reserve in the context of enhanced 2030 ambition. We believe the ambition level of the EU ETS could be even higher, while the ambition level for the ESR sectors could be respectively lower. Now the target (-61 % vs. 2005) for the EU ETS is increased with 10 percentage points compared to the BAU level, while the target for ESR is increased with almost as much: with 8 percentage points compared to the BAU level. The EU ETS sector has an efficient and liquid market system, where the market participants are typically companies, and emission reductions can be easily monetised. The ESR sector is under Member States’ responsibility and tends to have higher marginal emission reduction costs. Typically, there is no efficient market-based system to identify emission reductions in the ESR sector. Operators in the ESR sectors are e.g. municipalities, small companies, agricultural producers and private citizens. All in all, the situation already (with the current 30 % target) may lead to emission reduction costs of even 10,000 EUR/tCO2 in some specific policies in the ESR sector, while the price in the EU ETS is around 60 €/tCO2. An essential barrier for Bioenergy Carbon Dioxide Capture and Storage (BECCS) facilities in the current ETS framework is the lack of incentives for capturing and storing biogenic CO2. Even if the most BECCS potential might materialize after 2030, it is important to send the right signal for the industry now and fix the incentives already for 2020s’. We already have some significant BECCS projects in the pipeline in Europe. These projects should be enabled and supported to gain practical experience from this promising technology and to ensure technological progress in the learning curve. We note that the EU ETS proposal does not provide new incentives for BECCS and other negative emission technologies. We therefore look forward to the forthcoming carbon removal framework, which the Commission has announced for Q4/2022. We welcome the fact the EU ETS proposal now recognizes all different transport modes for carbon dioxide, including transport by ship or lorries, We also applaud that Carbon Capture, Use and Storage (CCU, CCS) are enabled as eligible project types for funding from the Innovation Fund, including with additional supporting instruments, such as carbon contracts for difference. Finally, we note that the new EU ETS proposed for the road transport and heating sectors creates a potentially cumbersome situation, where these sectors participate in the new ETS, but also remain regulated through the ESR – where each Member States needs to achieve its binding national target that is also supported with a strong compliance regime. Therefore, the possibilities and incentives for trade are limited. Without trade the new ETS does not really have purpose.
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Response to Land use, land use change and forestry – review of EU rules

8 Nov 2021

The Bioenergy Association of Finland welcomes the Commission proposal to revise the accounting methodology from 2026 onwards. Accounting becomes easier and more transparent and is consistent with the new formulation of the EU 2030 climate target adopted as part of the EU Climate Law. We also support the phased approach (2021-2025, 2026-2030, 2030+) the Commission has presented. We believe the most important decision at this stage regarding the time beyond 2030 is, whether or not to introduce the AFOLU sector. While we are open to explore the introduction of the AFOLU sector, we underline that the target adopted for the AFOLU sector needs to be evaluated separately and as part of the overall climate architecture proposed for the 2030-2040 period. The headline target (310 Mt) for 2030 seems consistent with the agreement achieved in negotiations on the European Climate Law. We note however that the target is significantly higher than the existing LULUCF sink and requires new policy measures. It is also important to note that this target, which is beyond the 225 Mt limit agreed in the European Climate Law, does not help in fulfilling the 2030 objective, but has been argued based on climate objectives beyond 2030. In a way, this is premature as all other climate objectives beyond 2030 (except 2050 climate neutrality) are still unclear and will be analysed and agreed later. All Member States should participate in contributing to any carbon removal target and the level should not be further increased beyond 310 Mt as this would unduly punish economic activities in an already carbon-negative sector and let fossil-fuel fired economic activities refrain from responsibility. If ambitious carbon removal targets are set for forest-rich countries for 2030, there cannot be Member States, which do not have removal targets at all, but may generate additional emissions in the LULUCF sector. The bare minimum for all Member States is to achieve climate neutrality in the LULUCF sector by 2030 with or without the use of flexibilities. We believe the method to determine the 2026-2029 pathways should be agreed at the same time as the 2030 targets for Member States. No delegated acts are needed here. As the EU raises ambition in the LULUCF sector, it is important that the use of flexibilities is also enabled. All existing flexibilities between Member States and different sectors within a Member State should be retained, and potentially, new ones also explored - in particular between the LULUCF and Effort Sharing Regulation Sectors. In Finland, peat has been extracted in drained areas with thick peat layer. Emissions from peat extraction in the LULUCF sector are now declining rapidly due to the EU ETS and peat production sites are being restored or afforested. Finally, we support the intention to extend the HWP article to new categories and would especially like to highlight the potential of biochar, where we already see positive development in many Member States, including Finland. Production of biochar can be fully integrated in the energy system so that the waste heat is fully utilized in a district heating/cooling system.
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Finnish Bioenergy Association seeks incentives for carbon removal technologies

7 Oct 2021
Topic — The EU is developing a certification framework for various sustainable carbon removal methods.
Message — The association requests financial and regulatory incentives for technologies like BECCS and biochar. They call for a long-term vision to provide investment predictability and clear targets.12
Why — The proposed framework would make bioenergy carbon capture technologies commercially viable and attract investors.3
Impact — Fossil fuel operators lose their unique regulatory advantage as bioenergy gains similar storage incentives.4
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Finnish Bioenergy Association urges revisions to biofuel certification rules

25 Jul 2021
Topic — Implementing rules for voluntary schemes certifying sustainable biofuels and biomass fuels.
Message — The association demands that rules align with the Renewable Energy Directive to avoid administrative burdens. They request a transition period and revisions to the list of wastes and residues.123
Why — These changes would lower compliance costs and maintain flexibility in biomass supply chains.4
Impact — Biofuel producers face raw material shortages if forestry residues are excluded from the list.5
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Finnish Bioenergy Association slams excessive EU forest biomass guidance

27 Apr 2021
Topic — EU operational guidance for demonstrating compliance with forest biomass sustainability criteria.
Message — The association urges the Commission to revise the draft to avoid stretching beyond its legal mandate. They request workable tools for verification instead of new definitions that interfere with national forestry policies.12
Why — Simplified reporting and clearer definitions would reduce compliance costs and prevent market turbulence.34
Impact — Regulators and environmental groups lose access to precise data from track-and-trace systems.5
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Response to Commission Delegated Regulation amending Regulation (EU) 2019/856 as regards the application procedure

14 Apr 2021

The Bioenergy Association of Finland would like to point out some key issues regarding the proposed changes to the current Delegated Regulation. It is important that the application procedure is efficient in order to accelerate the EU’s shift to a more sustainable economy. However, it also needs to be ensured that the application procedure does not rule out potential candidates with innovative solutions in low-carbon technologies and processes. Introducing the option for a one-stage application for the large-scale calls and thus eliminating the first-stage screening of applications, would result in a substantial increase in the amount of effort put into the application process. This does not support the original goal of lowering the barrier to apply which is one of the reasons why the two-stage application process was introduced to begin with. A full-scale application requires a massive amount of R&D resources and therefore the one-stage application could benefit the biggest operators. Channeling the investments solely to the biggest players in the field might not lead to the optimal outcome for innovation nor for climate change mitigation. Rather than moving back towards the one-stage application procedure it would be beneficial to maintain the two-stage procedure and e.g., specify the application requirements and the criteria regarding projects’ maturity level. This could reduce the number of those applications received which do not meet the criteria and thereby reduce the amount of required administrative work. The amendment proposed in Article 13 is a good addition to the procedure. The project development assistance can support the projects of insufficient maturity but having the potential to meet all selection criteria if further developed. This can further accelerate the implementation of successful projects fostering innovation in low-carbon technologies and processes. Considering the large number of applications seeking funding compared to the funding available, additional support for innovative clean technologies is needed to meet the EU’s climate goals.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

Bioenergy Association of Finland considers that general emission reduction targets in the ETS and ESR sectors should be the main drivers for action in companies and member state policy actions. Higher emission targets would bring concrete efficiency gains, as they indirectly incentivise improving energy performance, either through building renovation, renewing current heating systems, or transforming the energy systems. The first round of national energy and climate plans showed an insufficient level of ambition in Member States to decarbonise the heating and cooling sector, which accounts for half of energy consumption in the European Union. The residential sector accounts for 21% of EU energy consumption and the building sector needs a stable framework to close the gap which is evident based on the presentation of the long-term renovation strategies by Member States. In addition, there is a need for national governments to increase their NECP’s heating targets. We consider higher targets for renewable heating and cooling should be accompanied with non-binding measures in the Energy Performance of Buildings Directive (EPBD, option 2 of the inception impact assessment). Imposing ever more bureaucratic energy labelling or calculation requirements on building owners is not the right policy avenue. It is much more important to ensure affordable financing and subsidies to speed up building owners’ planning and to push it into action. When the investment shows a clear ROI in less than 10 years, the results are guaranteed. While heating and cooling represent half of the EU energy consumption, just 22% of this is renewable. More than 80% of renewable energy is provided by bioenergy. Biomass has also been recognised as the only cost competitive technology in the European Commission’s report on Competitiveness of the heating and cooling industry and services, having the potential to further reduce utilities bills to consumers, thus addressing energy poverty. There is no technology bottleneck to increase RES and low carbon District Heating in buildings with many solutions using solar, biomass or ground/ambient heat, sometimes in a hybrid system. Biomass equipment is now more and more efficient with very low emissions, ready to replace old appliances. What we need is a strong signal from the EU, going down to the country and local levels. In this sense, the Bioenergy Association of Finland believes the EPBD can be a bridge to achieve the new renewable and climate targets through a smooth implementation of the strategies until 2026 where further measure should be taken to be sure the new building stock is 100% renewable.
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Response to Climate change mitigation and adaptation taxonomy

13 Dec 2020

Commission Draft Delegated Regulation supplementing Regulation (EU) 2020/852 and Annexes plays a significant role in detailing how the financial sector in Europe directs sustainable investments. The taxonomy will serve as a guideline for voluntary financial activities, but is also planned to be used as a broader framework for instance for deciding on recovery packages, state aid and other public funding. It may also widely affect shareholder decisions. Therefore, it is of utmost importance to streamline the taxonomy to be coherent with other union legislation. The Bioenergy Association of Finland welcomes the improved alignment of the Annexes with the provisions of the Renewable Energy Directive 2018/2001, but still calls for a set of modifications to the criteria (Annex I and II) covering the bioenergy sector and its value chain: 1. Sustainable bioenergy meets the criteria set by article 10. 1 (a); (c) and (h) of Regulation (EU) 2020/852 and must therefore be referred to, as an activity contributing substantially to climate change mitigation. 2. Electricity generation from bioenergy (4.8 - Annex I): further streamlining with Sustainability Criteria of REDII needed (see Annex). 3. Manufacturing of biofuels (4.13 Annex I): general exclusion of feed and feed crops is non-aligning and counterproductive. 4. Cogeneration of heat/cool and power from bioenergy (4.20 - Annex I): further streamlining with Sustainability Criteria of REDII needed (see Annex). 5. Production of heat/cool from bioenergy (4.24 – Annex I): further streamlining with Sustainability Criteria of REDII needed (see Annex). 6.Installation, maintenance and repair of renewable energy technologies (7.6 - Annex I): integrate bioenergy installations in the individual measures listed. 7. Research, development and innovation (9.1 – Annex I): RD&I in the Bioenergy sector is essential to deliver on climate neutrality 8. Afforestation ( 1.4 Annex II): remove reference to bioenergy
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

One main objective for the revision according to IIA is to promote green transition. Bioenergy has been the main instrument in the EU for green transition in the past. The sector has still major potential to deliver, which is clearly acknowledged by the Commission in its 2050 long term strategy in November 2018 and in the impact assessment following the 2030 Climate Target plan in September 2020. State aid regulation should follow the relevant union legislation and align with different environmental and climate criteria in the legislation. Some examples are the REDII directive, the ILUC regulation and the sustainable finance taxonomy. When state aid rules are linked to the sustainable finance taxonomy it is necessary to ensure that linking is done in the framework of respective processes reflecting the circumstances, also national characteristics. The Bioenergy Association of Finland favours methods for state aid that are technology-neutral. Investment aid and public support to R&D together with carbon pricing schemes are the main instruments of choice. The revision of state aid rules should ensure that state aid does not distort functioning of the Emission Trading Scheme (ETS). It should also be noted that due to further energy integration of sectors there will be interlinkages in carbon price signals, too. We support the idea of broadening up the support schemes to environmental objectives other than decarbonisation. Objectives could, for instance, include supporting actions improving biodiversity and resource efficiency of undertakings. The current state aid rules – with prolongation of one year – are in our view broadly serving in a satisfactory way. Our sector has faced some restrictions set by the State Aid rules for the possibilities to support the growth of the sector during the past decade. Within the electricity sector low-carbon solutions have delivered. In our opinion, the ETS should be the main solution to incentivize low-carbon solutions in that sector. Even when electrification of society is progressing, we will still need a major share of ICE’s with biofuels & biomethane as well as bioboilers producing heat & electricity in the coming decades . More attention should be paid on the non-ETS. Average emission reduction cost there is much higher than in the ETS, up to 125 - 150 €/CO2-tn. Cost-effective actions are needed. We could produce negative emissions (NET) with bio-CCS and other technologies, but in our analysis the NET has not been well addressed in the current State Aid rules (e.g 3.6 of EEAG) In the transition to a circular bioeconomy more synergies between sectors are required. This implies more integrated processes and industrial symbiosis. Biofuels contribute significantly to reduced CO2 emissions compared to their fossil alternatives. During the coming years both food-based and second-generation biofuels are needed to decarbonise the transportation sector. This was also the outcome of the negotiations on the recast Renewable Energy Directive (2018/2001). The EU legislator decided not to phase out biofuels made from “food and feed crops” (term used by the Directive 2018/2001). Instead, these fuels – as long as they fulfil the sustainability criteria – should be eligible for support schemes in the Member States at levels attained by 2020. A prohibition of operating aid to any food-based biofuels would seriously hinder both the EU and its Member States to meet decarbonisation targets in the area of transport, including the 14% target for renewables in transport by 2030 under the revised Renewable Energy Directive. Member states should have their own discretion and flexibility to operate within the thresholds set by the REDII directive. Members states should independently resolve what kind of market development they wish to see to reach the targets, which in the end determine the levels and quality of biofuels used in 2030.
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Response to EU Forest Strategy

4 Dec 2020

The Bioenergy Association of Finland believes a transition from fossil-based economy to a circular bioeconomy is needed. We believe the climate targets of the EU need to be achieved mainly by reducing emissions from fossil fuels. Natural carbon sinks can simultaneously be enhanced in the long-term, but they cannot be a replacement for emission reductions or actions to enhance technological carbon sinks in Europe. The association aims to increase the share of renewable and domestic energy when Finland targets quitting the energy use of coal by 2029 and achieving climate neutrality by 2035. The use of energy peat in Finland is rapidly decreasing while the use of sustainable bioenergy is moderately increasing during 2020s’ in transport and heating. The association aims at maximising the added value from biomass and enhancing exports of high-value, sustainable and even carbon-negative products. Energy enables the development of a circular bioeconomy and is derived from different side-streams from forest industry, forestry, agriculture and waste management. Regarding the new forest strategy, we would underline that the strategy needs to be holistic and – as the role and economic significance of forests around Europe are vastly different - respect the subsidiarity principle of EU legislation. It is important that the added value of the forest strategy with regard to all the other EU initiatives, such as the biodiversity strategy, the adaptation strategy and the LULUCF regulation is identified early. We note that the significance of forests as a basis for economic activity is not dealt with in other initiatives and believe the forest strategy can be the key instrument to address environmental, economic and social needs all at the same time. We would particularly highlight the importance of combining economic, biodiversity and adaptation objectives and note that the greenhouse gas emissions and removals are already adequately addressed through the LULUCF regulation, Effort Sharing Regulation and the EU emissions trading scheme – all of which are currently under review in the Commission. The Standing Forestry Committee should continue to be a useful forum in forest-related policy issues, such as the design and implementation of the forest strategy. The roadmap envisaged by the Commission for development of the forest strategy seems to ignore the significant role of side-stream biomasses from forests in the European energy system and, in particular, in some specific Member States. Bioenergy from various side-streams must be maintained as part of the forest strategy for two important reasons: 1) the European energy system still heavily relies on fossil energy and sustainable forest-based bioenergy can help reducing this key problem and 2) sustainable bioenergy combined with a carbon dioxide capture, use and storage can create a negative-emission system, which are highly lucrative in fulfilling EU’s long-term climate aims and responding to the Paris Agreement.
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Response to Protecting biodiversity: nature restoration targets

2 Dec 2020

The Bioenergy Association of Finland supports the aim of the EU to address biodiversity loss and the degradation of ecosystems. The general objective of the proposed legislation is to restore degraded ecosystems, in particular those with the most potential to capture and store carbon and to prevent and reduce the impact of natural and man-made disasters. We would like to note in this context that the EU and its Member States have several instruments in place for managing carbon and greenhouse gas emission balance. Therefore, any restoration targets should fully focus on addressing and improving biodiversity, and not set any additional climate change related requirements for Member States. The greenhouse gas emission balance of the land-use, land-use change and forestry sector is already addressed through the LULUCF regulation, in which the Member States have discretion on and determine how to respond to the no-debit requirement. The roadmap notes that effective and coordinated contributions by all Member States are necessary to achieve significant levels of biodiversity restoration in the EU. As a general principle, any binding restoration targets need to consider the current differences in percentage and quality of protected lands in different Member States. Restoration and protection both aim at the same objective and need to be looked at together. If any binding targets are set, the targets need to be clearly defined and comparable. It must be clear through which parameters an area is deemed “restored” and why (some of the losses in biodiversity are caused e.g. by climate change). Restoration would need to be as cost-effective as possible both at the EU and Member State level. As forest policy is Member States’ competence, any restoration targets and restoration measures with regard to forests should be defined in Member States. In order to offset the costs of biodiversity protection and restoration, economic incentives, such as compensation mechanisms, should be developed. The goal could be the overall improvement of the state of ecosystems and biodiversity - not only the no-net-loss of biodiversity. The analysis and the toolbox available should make full use of and build on voluntary certification systems already in use and widely acknowledged by different interest groups. The established certification systems can greatly benefit work e.g. by their continuous criteria updating processes and dialogue with important stakeholders of biodiversity.
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Finnish Bioenergy Association urges crediting for renewable fuels

26 Nov 2020
Topic — The revision of CO2 emission performance standards for cars and vans.
Message — The association requests a move away from tailpipe-only emission measurements and the introduction of a voluntary crediting mechanism. This would allow renewable fuels to help manufacturers meet their CO2 targets.12
Why — This would boost demand for biofuels and ensure their continued use in road transport.3
Impact — Electric vehicle manufacturers might face stiffer competition from combustion engine vehicles using renewable fuels.4
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

The Bioenergy Association of Finland supports a well-prepared transition towards EU’s climate neutrality by 2050. Climate change is a transboundary problem, where coordinated EU action can supplement and reinforce national and local action efficiently. We note that the revision of the Effort Sharing Regulation (ESR) is closely linked to decisions taken with regard to the EU ETS and LULUCF. We do not support extending the EU ETS to road transport sector before 2030. The potential extensions of the EU ETS should not weaken the incentives currently in place for low carbon energy in Member States. In the context of the ESR revision and regarding the inception impact assessment of the Commission, we would support exploring Options 2 - 3. Additional flexibilities with regard to the EU ETS and LULUCF sectors should be explored. We believe Option 1 is too ambitious in this timeframe, in particular as the ESR was only recently agreed in the EU institutions.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

The Bioenergy Association of Finland supports a well-prepared transition towards EU’s climate neutrality by 2050. Climate change is a transboundary problem, where coordinated EU action can supplement and reinforce national and local action efficiently. A profound question in the proposed revision of the LULUCF regulation is its envisaged contribution to the enhanced EU 2030 Climate Target. The LULUCF sector is the only economic sector that deals with both emissions and removals and – as a whole – provides net removals i.e. negative emissions in the EU. In 2018, the net removal was around 294 Mt, which is around 7 % of EU’s GHG emissions (without LULUCF). It is important to stop to think what the “polluter pays” principle means in the context of enhanced ambition in such a sector. Does an entity that removes carbon from the atmosphere – and thereby provides a societal benefit - have the same obligations to contribute as an entity emitting more carbon into the atmosphere? The Bioenergy Association of Finland believes the essence of the “polluter pays” principle suggests that reducing greenhouse gas emissions in the EU e.g. through the EU ETS and the ESR must be the primary objective of the EU 2030 Climate Target. Enhancement of carbon sinks – be it natural or technological – should rather be incentive- than obligation-based and of complementary nature. We therefore object to Option 1 in the Inception Impact Assessment, as it would lead to further obligations for entities that are already generating negative emissions for other entities in the EU. It is important to recognize that opportunities to remove carbon or avoid emissions in the land sector are unequally distributed across the EU and that the economic significance of the land sector varies widely in different Member States. We strongly support incentives to substitute fossil-based materials with bio-based ones. Links between the LULUCF sector and other sectors (EU ETS, ESR) can be re-examined and potentially strengthened as proposed in Options 2 and 3. We believe it might be useful and also possible to introduce a carbon balance accounting system that would be solid enough to incentivise land managers for removals. In this context we want to emphasize the role of good forest management and many opportunities to increase carbon sequestration relying on improving management practices. Along with the options outlined it is essential to further develop and strengthen the MRV requirements of the LULUCF sector and put effort on making it more coherent with other policies.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

The Bioenergy Association of Finland supports a well-prepared transition towards EU’s climate neutrality by 2050. Climate change is a transboundary problem, where coordinated EU action can supplement and reinforce national and local action efficiently. The EU ETS will be an important - if not the most important - tool to implement the enhanced 2030 Climate Target and to effectively launch the monumental effort to achieve climate neutrality and, eventually, negative emissions in the EU. The EU ETS has proven its ability to reduce greenhouse gas emissions in the Union. It is technology-neutral and provides plenty of flexibility for its participants to fulfil the related obligations. The Bioenergy Association of Finland therefore strongly supports significantly strengthening the EU ETS and reviewing the rules for the Market Stability Reserve in the context of enhanced 2030 ambition. We do not support extending the EU ETS to road transport sector before 2030. The potential extensions of the EU ETS should not weaken the incentives currently in place for low carbon energy in Member States. Bioenergy Carbon Dioxide Capture, Use and Storage (BECCUS) plants can be very useful tools for the EU in achieving its long-term objectives, as they can create an energy system with negative emissions. An essential barrier for BECCS facilities in the current ETS framework is the lack of incentives for capturing and storing CO2. We therefore warmly welcome the intention of the Commission to improve support for low-carbon and carbon removal investment as part of the ETS revision. Even if the most BECCS potential might materialize after 2030, it is important to send the right signal for the industry now and fix the incentives already for 2020s’. We already have some significant BECCS projects in the pipeline in Europe. These projects should be enabled and supported to gain practical experience from this promising technology and to ensure technological progress in the learning curve. We look forward to the Commission analysis on incentives for carbon removal in the context of the EU ETS. The analysis should include the option to have new incentives for BECCS within the EU ETS as well as in a separate incentive system. It is also useful that the Commission assesses the different EU ETS-based support instruments regarding incentives for carbon removal. The analysis and the legislative proposals due in June 2021 should ideally also make clear the overall view of the Commission on progress with carbon removal in the EU. We refer here in particular to the forthcoming carbon removal framework, which the Commission has announced for 2023. It is also worth noting that the revised Renewable Energy Directive will ensure that only sustainable solid and gaseous biofuels will have zero emission factor in the EU ETS as of January 1st 2022.
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Finnish bioenergy group demands stability over renewable directive revision

21 Sept 2020
Topic — A consultation on updating the Renewable Energy Directive to meet 2030 climate goals.
Message — The association requests keeping the current directive to ensure stability for business operators. Any revision should focus on increasing targets rather than modifying sustainability rules.12
Why — Avoiding revisions prevents regulatory disruption and protects the market position of bioenergy producers.34
Impact — Conservation groups lose the chance to enforce stricter sustainability standards for biomass feedstocks.5
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Response to EU Methane Strategy

5 Aug 2020

The Bioenergy Association of Finland welcomes the initiative to reduce methane emissions and supports joint efforts to decrease GHG emissions in general. The Commission is working on an integrated strategy covering the areas of energy, waste and agriculture to tackle the emission of methane and finding synergies between sectors, such as production of biogas. Another very important synergy is increasing recycling of nutrients and improving the quality of nutrients. This offers the advantage of less GHG emissions (by using biogas instead of fossil energy) and replacement of fertilizers produced by fossil energy (by using recycled nutrients). Agricultural emissions of methane are the result of natural microbial processes and it is not possible to eliminate the methane emissions in total. It is also a challenge to monitor and verify the greenhouse gases in the agricultural sector. Most of the potential methane feedstock would be available via waste handling steps by digestion, syngas through gasification or pyrolysis of biomass resulting in biogas. However, it is also possible to reduce the greenhouse gas impact from agriculture through efficient farm management which promotes soil carbon sequestration and especially using manure for biogas production. Manure is a natural source of methane and can - when properly processed - generate heat, power and even be used as transport fuel. In Finland there are few methane emissions left in the waste- and energy sector. This should not lead to a disproportionally large burden in the agricultural sector. Efforts are needed from the Commission to support investing in biogas production and recycling of nutrients. Sustainability and climate goals should lead to a competitive advantage – not reduce production. It is also important to detect and reduce methane emissions in producing and handling biogas. The production of biogas including landfill gas is in Finland about 1 TWh/a. Landfill gas in systematically collected from all old landfills. An expert group announced (based on Natural Research Institute reports) early this year that the theoretical potential of biomass for biogas in Finland is 16 TWh. According to a comprehensive group organization connected to agriculture, relevant industry and handling of waste, it is possible to grow the production of biogas to 4 TWh, mostly by manure until 2030, if sufficient incentives are in place.
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Response to EU Strategy on Adaptation to Climate Change

30 Jun 2020

We focus our comment on adaptation in forest management. Forests covers 43 percent of EU’s land area and provide renewable products and energy in addition to other ecosystem services, such as a habitat for species and recreation. Bioenergy is the most important renewable energy form in Europe and will remain so and grow during the next decade. This initiative of the Commission will help to understand the links between adaptation to climate change and different forest ecosystem services. Climate change has already caused unpredictable forest fires, bark beetle damages with considerable effect on timber market, sawn wood market and solid biofuel market. The economic losses of forest fires etc. are growing and market disturbances cause remarkable losses for industry. Even if it is not desirable and should be prevented to the extent possible, the market can in in the future have a significant oversupply of low-quality timber and pulpwood due to different disturbances. The bioenergy sector can be used as a last resort vehicle to respond to this oversupply. It is very important also in the future that wood can be used for different kinds of products such as houses, furniture, paper products and energy according to market driven cascading. For biodiversity climate change is a serious threat and there will be several losses in biodiversity especially for northern species. Increasing storms, forest fires, drought, pests and diseases imply permanent changes in biodiversity compared to the current situation. Climate change will also affect the growth of forests, which is critical for EU’s climate neutrality aims. Both the forest carbon sinks and the existing carbon storage in old forests are at risk because of climate change. Old forests in protected areas are unfortunately also a health risk for other forests surrounding them. Active forestry can be used to maintain healthy forests with potential restricted interventions in protected areas. In non-protected areas, a favorable age distribution can be maintained with active forestry. However, it is necessary to manage forests in a way that leaves more decaying wood in order to maintain and improve biodiversity of the species thriving on that phenomenon. Biodiversity means diversity in forests of all ages. Forestry practices developed in a broad cooperation and adjusted for national conditions are often a cost-effective alternative to protection for many species. The forthcoming Forest Strategy can become a key document for adaptation to climate change in forest management and keeping our forests healthy with high biodiversity values, while we at the same time produce ecosystem services and wood for products and use different side-streams for energy.
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Response to Strategy for smart sector integration

8 Jun 2020

Electrification is already ongoing. Replacement of oil, natural gas and coal with clean electricity is a welcome development. It is an ambitious goal to achieve. At the same time two other aspects should be considered in the equation: the total efficiency and carbon balance of the desired energy system and the embedded costs. We would caution against replacing biomass-based fuels with clean electricity without looking carefully at the overall context. Many uses of biomass fuels are supply-constrained and electrification can provide the needed additional capacity to replace fossil fuels in the energy system. In other cases, a certain amount of biomass fuels is produced to the market every year since they are residues and by-products from other activities, such as agriculture, forest industry and forest management. Replacing residues and by-products in the energy system is not an efficient means to cut GHG emissions unless there are new innovative uses for them. Residues left in nature are emission sources and over time remove short-term climate benefits. Bioenergy could contribute to flexibility and sector integration in several ways; maintaining synchronous inertia, ramping up and down when intermittent RES varies, storing energy in different forms in longer cycles, converting biomass to gaseous and liquid transport fuels specially for heavy transport. It is very essential to include all sectors (including transportation and heating/cooling) into sector integration discussions and the policy framework. Some biomass heating plants can be operated with rapid (minutes) ramp-up and ramp-down cycles in scales up to tens of MW. These can complement energy storages and electrification of heating. Bio-CHP-plants and biorefineries should be regarded as fundamental parts of the European energy systems. They can adjust the output of electricity and heat using more energy inputs for the production on low demand. In a high market demand they can delay or cut down some production. Plants can change their operation pattern during different seasons. For exampIe, the plants can use more energy to dry biomass to produce pellets. Within refineries, larger energy plants or industrial areas it is possible to balance excess electricity supply in various processes by storages, producing hydrogen etc. Bio-oil production can also be one new flexibility component of a CHP-plant. Biomass gasification produces synthetic gas which can have a high hydrogen content, too. Syngas can also be used as feedstock to produce several chemical components, such as ammonia, alcohols and waxes. A new piece in the energy system puzzle is the capture of CO2. Carbon dioxide capture and utilisation (CCU) and/or storage (CCS) may be combined to serve balancing. When there is excess electricity and hydrogen may thus be produced, the captured CO2 can be used to produce synthetic gaseous and liquid biofuels with the hydrogen. In a low supply situation, the CO2 can be transported to the storage supply chain instead. Production of carbon-negative biochar in smaller and semi-large facilities has similar seasonal, monthly and even daily flexibility characteristics, when condensates and gases from the production can either be used in the boiler, refined to be used as a transportation fuel or stored depending on the situation. Sector coupling can create undesired effects in the system. Producing a high share of hydrogen with reformation from natural gas can have substantial carbon footprint and the whole natural gas infrastructure gets incentives. If the production is based on electrolysis, the total electric efficiency of the energy system can be less than 40 – 50 % due to energy losses. It is advisable to critically compare different types of energy storages and look at the total capacity required and the unit cost of capacity. Storing to large water tanks and district heating networks can offer a very competitive solution over electric batteries and electrolysis pathway.
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Bioenergia ry urges Euro 7 to support renewable fuel use

2 Jun 2020
Topic — This consultation addresses stricter Euro 7 emission standards for combustion-engine vehicles.
Message — Bioenergia ry requests that the regulation promote alternative renewable fuels and maintain technology neutrality. They argue the Commission must prioritize solutions that are economically and technically available.123
Why — This approach would protect the market share for bioenergy products in transport.4
Impact — European citizens face the risk of mobility becoming disproportionately expensive.5
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

The Bioenergy Association of Finland welcomes the opportunity to provide feedback to this initiative. We believe regulation should be first and foremost technology-neutral by defining the target but not the technical means to achieve it. Alternative fuels are clearly an important means to reduce harmful effects of transport. Alternative fuels should not be mainly based on fossil fuels, but should clearly include sustainable biofuels (HVO, biodiesel, ethanol, LBG, SNG etc.) and biomethane (CBG). The market for alternative fuels is still in a relatively early development phase and the overall market share of vehicles using alternative fuels is still relatively low. It will unnecessarily remain so unless legislation gives vehicle manufacturers incentives to develop and manufacture combustion engines enabling the utilisation of high blended and pure biofuels and biomethane. This is possible by considering the use of renewable diesel (HVO), E85 and biomethane when defining European vehicle emissions standards. Vehicles using pure biofuels should for a good reason be considered as zero- or low-emitting vehicles. Developed combustion engine technologies together with high blended biofuels ensure vehicles on EU roads are clean over their lifetime in the coming decades. We want to accelerate the shift to sustainable and smart mobility. The use of high blended biofuels (including biomethane and synthetic methane, SNG) is one of the cost-effective ways to contribute to the enhanced emissions reduction target for 2030 now planned in the Commission. New effective vehicles using high blended alternative fuels such as HVO, E85, biomethane or SNG should be considered as low-emission vehicles. Regulation should be put in place to promote the manufacturing of engines with high efficiency and the use of high-blended or pure alternative renewable fuels. This market of alternative fuels will develop much faster in the future and the rising share of alternative fuels will accelerate the growth of the low-emission and zero-emission vehicle fleet.
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Response to Climate Law

1 May 2020

Please see the attached file.
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

Bioenergia ry – the Bioenergy Association of Finland welcomes the objective of the taxonomy to accelerate economic activities considered environmentally friendly and supporting the growth of low carbon sectors. At the same time, it is of utmost importance that the taxonomy reflects the existing business framework of companies. In the presented roadmap, reference to Art. 14 of the Taxonomy Regulation, including the requirement to assess the alignment of the technical screening criteria with the existing EU legislation, is important. We call for coherence with the existing legislative framework according to article 14. Metrics and screening criteria will be in a decisive role in determining how applicable the taxonomy will be. Unfit or impractical criteria will move investment away from those sustainable activities that cannot bear the administrative costs of compliance. This legal initiative will rely on the work of the TEG. we welcome this opportunity to react to the recently published TEG report. The final report acknowledges the essential role of bioenergy to ensure the decarbonisation of EU economy, yet the metrics are still inconsistent with REDII and could seriously hamper the sector’s competitiveness. We welcome the inclusion of bioenergy equipment suppliers in the list of Manufacture of Low Carbon Technologies. It should be pointed that the EU has a strong position e.g. on the field of bioenergy related technology with more than 80 % of bioboilers in last 10 years sold globally are from EU-based companies and over 70 % of the technology supplier companies of this sector are based in the EU. We welcome the conversion efficiency requirement set for bioenergy technology. However, it is important to specify that on REDII art 29(11) conversion efficiency is applicable only on electricity. In a delegated act the inclusion of bioenergy technology for the production of CHP, heat/cooling and transportation should be clearly stated, too. It is clear that the recast of REDII-directive, published in the end of 2018, constitutes a solid basis to guarantee sustainability of the sector. National implementation of REDII is ongoing and national laws should be in force in July 2021. Any inconsistency of metrics and thresholds selected in the TEG report with the existing legislation is therefore a concern as it creates double standards and barriers for business, and would in the end hinder economic activities to mitigate climate change. The TEG report introduces an all-encompassing incremental 80% GHG emission reduction threshold. The threshold is not in line with the one imposed by REDII. TEG’s proposal is that for the production of biomass, biogas and biofuels only feedstocks listed in Annex IX part A are eligible. This fundamentally contradicts REDII where sustainable bioenergy has clear requirements; broad spectrum sustainability criteria and GHG-emission thresholds. The screening criteria proposed for the forestry sector are not aligned with the existing legislation nor reflect realities of the forestry-based industry sector. For example, to follow feedstocks to forest stand is virtually impossible, let alone practical or economic. That is why REDII created the risk- based assessment approach operating at the macro-level. We want to emphasise that long-term predictability and consistency of regulation are very important for the capital-intensive energy industry. It would simply be counterproductive to risk the financing of projects that offer a significant contribution to climate change mitigation due to legislative inconsistency or an insufficient sustainability assessment. We recommend that the risk-based approach is fully adopted as a mitigation response and its alignment with REDII directive and the LULUCF regulation are ensured through a delegated act.
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Response to FuelEU Maritime

24 Apr 2020

We appreciate the opportunity to comment this important initiative, which supports achieving necessary GHG emission reductions in maritime transport. The use of low- and zero-carbon alternative fuels, including biofuels, presents an immediate solution with a significant reduction potential. The development and uptake of these fuels will be critical for achieving a more sustainable future for maritime transport. For transforming waterborne transport more sustainable and environmentally friendly, a reliable and predictable legal framework is the key. Maritime investments are long-term, 25-30 years, and high-risk. There must be supportive legislation in order to steer the investments to the right direction. In addition, the distribution, storage and bunkering infrastructure of low- and -zero carbon fuels need to be secured. For securing the necessary supply of low- and zero-carbon fuels, a sufficient scale of production is needed. A supportive legislation, such as RED II, is the key to create a framework for demand and thus enabling production capacity investments. This initiative has a holistic approach and considers several options such as extending the EU ETS, tax exemptions etc. At this stage, the policy options outlined are however quite vague and not at the same level of maturity. A flag-neutral approach helps to ensure a level playing field for shipping companies and brings several advantages, for example preventing potential carbon leakage.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

Regarding the proposed roadmap, Bioenergia ry - the Bioenergy Association of Finland would like to highlight some key issues which need to be taken into consideration by the European Commission. As for the Inception Impact Assessment, making legislation consistent and interfaces more fluent between various regulations is welcomed, but overlapping legislation must be avoided. Greenhouse gas emissions and circular economy are already dealt with in other legislation (see below). Broadening the scope of the IED to installations with a rated thermal input equal to less than 50 MW is unnecessary since those installations are already regulated under the Medium Combustion Plant Directive. There is no regulatory gap to be filled with broadening the scope to installations in current sectors just below the existing threshold. The necessity of adding sectors that fall outside the scope of the IED should be carefully assessed and consulted with the relevant stakeholders and industrial sectors and a thorough impact assessment should be carried out in advance. Circular economy and decarbonisation of industry are both important targets for the EU and the IED should be consistent with these objectives. There is plenty of other legislation already in place focusing on these objectives. Greenhouse gas emissions are already regulated under the EU Emissions Trading Scheme (ETS) and therefore the IED should not include GHG-emissions abatement measures. Further measures to reduce GHG-emissions from industry should be focused on strengthening the ETS. As for the circular economy, the relevant promoting actions are mainly based on a value chain approach whilst the IED focuses on a single installation. These issues should rather be considered under IED so that permitting does not unnecessarily delay or hamper introducing the activities and technologies promoting these policies. In case the activity or technology is clearly relevant in the pursuit of low-carbon or resource-efficient system, this should be regarded as positive. Also, the other possible environmental requirements should be evaluated in this context in order to keep these investments as attractive as possible. In the current IED, the Article 42 should be clarified as it now excludes certain gasification and pyrolysis plants from the scope. In some cases, the competent authorities are unable to give permits for certain clean technologies because of the unclear regulation. A non-paper of this issue was published in 2018. Again, it should be assured that the IED regulation does not unduly create barriers for any climate positive actions. The IED remains relevant to its overall objective to address emissions to air, water, and soil and to prevent the generation of waste, in order to achieve a high level of environmental protection as a whole. IED's purpose and objectives should mainly maintain as they currently stand. Attention should be paid to avoid overlaps, contradictions, or inconsistencies with other relevant EU legislation.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

20 Apr 2020

We appreciate this important initiative on sustainable aviation fuels (SAF) and the opportunity to comment. This initiative will help to achieve reductions in GHG emissions from aviation. The use of SAFs present an immediate solution with significant reduction potential. The wide-spread use of SAFs, in combination with other measures, will be critical for the improvement of the environmental footprint of the sector and achieving a more sustainable future for aviation. In order to ensure that the aviation sector can benefit from this, the EU and its Member States will need to support the supply and demand of SAFs in the EU in order to overcome the existing challenges. Technological innovation and advancement will provide the basis for further carbon emission reduction opportunities for the mid-to-long term. We agree that competition and market issues must be guarded to avoid distortions. We still believe that the EU state aid rules should allow for forceful economic interventions in this area to meet the ambitions on climate and environment of the EU. Technology neutrality as well as sectoral neutrality are important principles, i.e. the Commission should promote biofuels in all transport sectors equally. If revised, because of the ambition level of the European Green Deal, REDII Annex IX should not be opened. It should be confirmed, however, that eligible and sustainable waste and residue feedstock can be included in Annex IX with reasonable bureaucracy. We strongly agree that there is no need to develop specific sustainability requirements for aviation. All sustainable feedstock/biofuels complying with RED II are needed and there are waste and residues not mentioned in RED II Annex IX that are eligible and reduce GHG emissions. A wide feedstock availability and technology neutrality are crucial for increasing the use of biofuels in aviation. The policy options and combinations of measures mentioned seem to be relevant and comprehensive in order to improve the environmental footprint of aviation.
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Response to 2030 Climate Target Plan

15 Apr 2020

The Bioenergy Association of Finland supports the objectives of the EU Green Deal, including climate neutrality by 2050, healthy ecosystems in the EU, improved competitiveness for European industries and higher energy security. A broad global coalition of countries implementing ambitious climate policies together should remain as the overall goal for EU’s climate diplomacy as this is the only way to make a meaningful dent on global emissions. The EU has succeeded in leading and should continue to lead and push for progress in such a broad coalition through its own convincing policies. A broad coalition of ambitious countries would also create a demand pull for cutting-edge clean technologies and products developed in the EU and elsewhere. Whether such a coalition exists or can reasonably be extended in the near future should be taken into account, when the EU re-examines its 2030 emissions reduction target. We believe it is a good basis that the initiative will assess the economic, social and environmental impacts and provide elements of the overall broad architecture of policy measures across sectors to achieve the revised climate ambition. This should include proposals for: - the 2030 emissions reduction target based on its analysis - the revised EU ETS emissions reduction target (EU level) and its possible extensions - the revised target for the effort sharing sector (EU level) The clear focus of the increase of the 2030 target must be in emissions reductions, in particular in lower use of fossil fuels. We do not believe the LULUCF regulation or the RED2 Directive should be reopened at this stage. Regarding extensions of the EU ETS, we consider intra-EU maritime transport as an option. We do not support extension of the EU ETS to the road transport sector in the 2021-2030 timeframe. The legislative proposals that the Commission plans to review by June 2021 include all the relevant climate and energy legislation agreed over the past few years. We note that there are two kinds of legislations that are listed. Whereas the EU ETS and Effort sharing deal with emissions reduction targets, there is also legislation listed, such as the RED2 and energy efficiency directives, which rather deal with the rulebook on how those targets are met. The LULUCF regulation contains both elements. We believe the focus of implementation of a potential increase in the 2030 target should be in amending the targets. The rulebook was very recently agreed and the RED2 and energy efficiency directives should not be reopened now, since any such move would slow down investment. It is also worth noting that in its proposal for European Climate Law in March 2020, the Commission deliberately excluded the option of reducing emissions or increasing removals outside EU’s borders. Such framing almost automatically implies a higher price of carbon and higher mitigation costs for the EU. This applies also for the 2030 timeframe. Higher ambition in the 2030 target could be achieved (with the same cost) if the EU partly allows emissions trading beyond its outer borders. What is also planned to be assessed in the initiative is how the EU can increase the absorptions of CO2 emissions over time, “including in its natural sinks and the role of biomass-based products and nature based solutions”. Technological solutions like BECCS/BECCU are not mentioned, even if the Impact Assessment of the 2018 long-term climate strategy communication highlights the importance of these in achieving the 2050 climate neutrality target. We believe the initiative should already outline how the Commission plans to proceed in order to enable and support these technologies in the 2020-2030 timeframe. This should also include a description of the objectives and framing of the forthcoming “Regulatory framework for the certification of carbon removals” (planned for 2023) and its proposed link to the 2030 energy and climate framework.
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

The Bioenergy Association of Finland supports the objectives of the EU Green Deal, including climate neutrality by 2050, healthy ecosystems in the EU, improved competitiveness for European industries and higher energy security. Development of carbon border adjustment (CBA) mechanisms requires, however, careful assessment. CBA-mechanisms are always second-best options in climate policy – even more so if they are unilateral. Multilateralism i.e. a broad global coalition of countries implementing ambitious climate policies together should remain as the best option and the overall goal for EU’s climate diplomacy. The EU has succeeded in leading and should continue to lead and push for progress in such a broad coalition through its own convincing policies. A broad coalition of ambitious countries would also create a demand pull for cutting-edge clean technologies developed in the EU and elsewhere. The Commission should analyse whether CBA mechanisms are indeed necessary and the best policy avenue for the EU. If that would be the case, the Commission should in its communication propose, under which conditions CBA mechanisms should be introduced. The problem definition for CBA mechanisms begins with the presumption “As long as many international partners do not share the same climate ambition as the EU, there is a risk of carbon leakage.” In this context, it is worth noting that in its proposal for European Climate Law in March 2020, the Commission deliberately excluded the option of reducing emissions or increasing removals outside EU’s borders. Such framing almost automatically implies a higher price of carbon and higher mitigation costs for the EU, as likely more cost-effective mitigation options outside the EU where “the same climate ambition is not shared” cannot be utilized. It therefore seems that the need for CBA mechanisms is partly dependent on whether the EU is open for emissions trading across its outer borders. There is hardly any experience – even at technical level - about the use of CBA mechanisms. Implementation of such mechanisms in US or Canadian States is indeed worth exploring, but at the same time, it needs to be recognized that they are not comparable with the EU introducing such mechanisms for global trade. We note that the planned roadmap is planning to carefully consider different types of policy instruments, methodological approaches for technical implementation and sectoral scopes. While all of this is useful, the Commission should also analyse and evaluate the political counterparty risks of CBA options, including risks like trade wars and backsliding in global implementation of the Paris Agreement and in the UNFCCC. These kinds of risks may be difficult to specify and quantify, but can be immensely important for decision-making in the EU institutions and should not be ignored. If CBA mechanisms were introduced, that should take place gradually. The focus should first be in a few sectors, which are import-intensive (at EU and/or MS level) and where products are emission-intensive. The electricity generation sector with fossil fuels might be one of the candidates.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

Please see attachment.
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

12 Mar 2020

It is essential and responsible to ensure a fair energy transition in the designated ”carbon intensive areas”. The Association supports JTF with profound planning and careful preparation engaging the areas designated as soon as the final decisions will be made and the criteria will be available. The NUTS 2 areas of Eastern and Northern Finland (the main cohesion policy areas in Finland) were mentioned as the most affected regions in the Commission country report of Finland on 27 February 2020. However, the peat extraction areas and employment are located mainly in the Western and Central parts of the country, where the decline of energy peat is assumed to be most severe and rapid. It would be fair to include those regions in the measures eligible for the JTF funding. JTF would help to create a path to diversified sources of living and regenerating rural areas that are ecologically, economically and socially sustainable. Special attention should be paid to justification and motivation at regional level to redirect the social and structural development funds and to mobilize the needed private and public co-funding in just transition strategies and plans. The needs of the affected regions are different and also changing continuously. Self-relience should be promoted and trusted, which should result in flexible just transition plans. Only this way the commitment to sufficient co-funding can be secured and ultimately the goals of JTF met in the future. The just transition actions partly funded from JTF should ”leave no one behind” also from the client point of view. This principle should be considered also in timing and include those sectors dependent on availability of peat in security of supply situations. Peat is produced for many other purposes than energy - for growing media substrate, animal bedding and health, balneology and cosmetics, compost additives, absorbents and activated carbon. Many of these uses are important to local and regional economies without real alternatives and substitutes in a market with growing demand. However, the overall volume of extracted peat will decrease in the future due to the strong decline in the use of energy peat. In the process of planning just transition one should have a balanced view and holistic approach not to cause harm to indispensable other uses of peat. All the means including the JTF should be utilized for the purpose in the designated areas. It is also worthwhile to activate just transition measures funded by the JTF regardless of the size of participating enterprises. Many investments on circular economy and low-carbon solutions require also participation of larger companies and collaboration over the regional boundaries. Building up such skills and networks may benefit from the additional resources of JTF. In order to meet renewable energy goals the regions suffering from the loss of energy peat employment would need more work force. For those people that used to extract energy peat, it would be a lot easier to take up a job in an adjacent field and utilize the experience gained. Sourcing of sustainable biomass is one example and provides stable, long term benefits for local economies. For example, production of biogas and biochar, installations, silvicultural operations and energy entrepreneurship can be promoted with further education tapping the JTF cofunding. In service training and flexible forms of adult education would likely produce results cost effectively for those seasonal workers typical for peat production and supply chain. Making the optimal use of what is already present will reduce the costs of the transition and also ensure that as many jobs as possible can be maintained while new jobs are created.
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Response to Climate Law

6 Feb 2020

Please see the attached file for our feedback.
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Response to A new Circular Economy Action Plan

20 Jan 2020

We hope the New Circular Economy Action Plan will get a significant role in the Green Plan. We see Circular Economy as an important part of the discussions on energy transition & climate change mitigation. The most effective policy to advance circular economy is to prevent new waste from being generated. We encourage considering further actions that focus on upstream activities of the product chain. Today, renewable materials can increasingly replace materials based on non-renewable resources, and it is important to identify and utilise these opportunities. Customer information on products and rules for marketing of products specially made of non-renewable raw materials is highly supported. Regarding energetic use of waste, we hope the emphasis will be on improving efficiency of Waste-to-Energy plants and refining of feedstocks into more valuable energy products. It is even possible to achieve negative greenhouse gas emissions in Waste-to-Energy plants using bio-based waste through capture and storage of CO2 from flue gases. ‘Externalising’ materials to non-EU countries in absence of EU facilities that could utilise those material in re-use is a valid concern. It should also be noted that a high end-use cost for recycling of renewable materials may be an incentive to use non-renewable materials instead. This may often be a counterproductive signal towards the aims of a circular economy.
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

We support the proposed roadmap for preparation of the biodiversity strategy. It is important that the EU addresses the remaining challenges in a well-prepared, targeted, balanced and cost-effective way. In order to reach this, Member States should actively participate in a bottom-up approach. 1. Effective implementation of existing EU-policies should be ensured. 2. The new strategy should take into account the current differences in percentage and quality of protected lands in different Member States. It is also vital to recognize the differences of Member States with regard to the economic role of managed forests and their role for energy security. 3. The strategy should address synergies and trade-offs with e.g. climate change mitigation. 4. The strategy should make full use of and build on voluntary certification systems already widely in use and acknowledged by different interest groups. The established certification systems can greatly benefit the EU 2030 biodiversity strategy e.g. by their continuous updating processes and dialogue with important stakeholders of biodiversity. 5. Irrespective of whether the actions to improve biodiversity are based on legislation or on voluntary actions we need effective financing instruments to speed up the actions. Increasing biodiversity in parallel in conservation areas and in forests and agricultural land that are in economic use can provide faster and deeper results. We support enabling “the implementation of the strategy by securing adequate financial resources, improving knowledge and engaging citizens and stakeholders across sectors. “ We see the need to further develop models and incentives for farmers and forest owners that can create the necessary push. The EU could look into the possibilities to establish a fund with private investors to finance acquisition of new conservation areas. This way participation to protection of biodiversity could be fair, market-based and more equitably dispersed between EU member states. 6. We also support the target to “promote the sustainable use of forest, agriculture, marine, freshwater and urban ecosystems”. Several pieces of legislation already contribute to this direction, but it can take some time to get the results in our nature. The EU’s land use is facing multiple challenges simultaneously: climate change mitigation, biodiversity loss and urbanisation to name few. It is not an easy task to solve all of the issues on the same land area. Land use planning needs a multi-disciplinary approach where synergies are considered. New digitalised systems can help in adding several layers of data and optimise the land use based on the best available information and local and national decisions. 7. In our understanding there are large differences in up-to-date information on biodiversity development across Europe. This is an obstacle to effectively plan and monitor actions, and the quality of the data is key in any new strategy. It is crucial to improve the quality with the best available technology and secure a race to the top vs. a race to the bottom in that regard in EU member states. 8. Finally, we would like to draw attention to the possible risk of externalisation of biodiversity effects outside the Union. We encourage to deepen understanding and cooperation on statistics of consumption and the related external effects.
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Response to Update of the 2012 Bioeconomy Strategy

20 Mar 2018

The Bioenergy Association of Finland represents the entire Finnish bioenergy sector from land ownership to forest industry and energy companies, as well as technology and research in the field and has around 300 member organisations. We fully support the overall goal of the update of the 2012 Bioeconomy Strategy to seek a long-term balance of different objectives. We would like to underline the following points in the update: - the Commission’s initiative rightly points out that global interconnected challenges will affect European food systems, which needs to be recognized in the update. We would like to point out that forests are also strongly affected. This may have significant environmental, economic and social impacts in different parts of Europe. - bioenergy in Finland – and in many other parts of Europe - is primarily based on sidestreams (e.g. thinnings, logging residues) of forest management or of forest industry (e.g. bark, sawdust, pellets. As clearly demonstrated by the recent report by IRENA, bioenergy needs to play a key role in European Energy supply - also in the case the EU is increasing the share of renewable energy beyond 27% of final energy consumption by 2030. The update needs to recognize this while supporting development of circular bioeconomy and new and innovative biomass-based products, seeking high value added, and enabling a healthy competition for biomass. In particular, the update should promote high ambition in replacing fossil fuels with renewable energy. As the task is enormous, all feasible technologies should be fully utilised. Priority should be given to resolute continuous progress, not to 100 % pure ideals. One way to support high ambition is thereby to also enable gradual and flexible solutions, such as high efficiency co-firing, in both transport and heat and power generation. - synergies between multiple objectives, such as environmental protection and bioenergy supply should be promoted. Such synergies can be found e.g. in utilization of biogas stemming from agricultural biomass, or even from harvesting of alien invasive species in water systems. - the update of the bioeconomy strategy should build on existing and forthcoming legislation (such as the EU ETS and the RED2 directive) and market-based systems to determine the best use for biomass. - the bioenergy sector provided 489,000 jobs in EU-28 in 2015 and was clearly the largest renewable energy source in terms of job creation. (AEBIOM 2017) This social and economic role of the bioenergy sector needs to be recognized in the update. - neither the forestry sector nor the bioenergy sector can thrive in the long run if the growth of forests is seriously affected by e.g. increasing forest damage or forest fires. Therefore, it is essential that the update of the bioeconomy strategy also aims at increasing resilience of and adaptation in European forests. - the bioeconomy strategy should also align with the new 2013 Forest Strategy. There are great examples of multipurpose use of biomass. Many examples can be found in forest industry combinates, where incoming wood material is efficiently refined into several products ranging from every day hygiene products to construction materials and components, bio-chemicals, different pulps and not least energy products. Other cases show that bioeconomy can also work in more decentralised manner. For example 600+ Finnish small-scale heat entrepreneurs use local low quality wood as chips to heat villages and enterprises and at the same time replace fossil fuels. Energy use of these wood materials also incentivises forest management and supports forest growth and possibilities to further produce bioeconomy products. Bioeconomy should be understood not only as the complicated biorefining plant complex but also as a web of enterprises that creates jobs and versatile products and services for transition from a fossil-economy towards a circular bioeconomy.
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