Suomen Biokierto ja Biokaasu ry
SBB
Finnish Biocycle and Biogas Association promotes nutrient recyling and the use and development of biogas technology and its knowledge in the society.
ID: 379219338785-37
Lobbying Activity
Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)
13 Oct 2025 · Circular Bioeconomy CAP Structure
Response to Circular Economy Act
6 Oct 2025
Suomen biokeirto ja Biokaasu ry (SBB) kiittää mahdollisuudesta toimittaa lausunnon EU:n kiertotalouslakiin. Liitteestä löydätte SBB:n lausunnon kokonaisuudessaan. Suomen Biokierto ja Biokaasu ry pitää tärkeänä, että Euroopan unioni edistää siirtymää kiertotalouteen perustuvaan biotalouteen, joka vahvistaa Euroopan kestävyyttä, kilpailukykyä, huoltovarmuutta ja pitkän aikavälin resilienssiä. Tämän toteuttaminen biologisten resurssikiertojen sulkeminen, sivuvirtojen ja jätteiden tehokas hyödyntäminen sekä maaperän ja ekosysteemien terveyden parantaminen edellyttää laaja-alaista ja järjestelmätason politiikkamuutosta. Pidämme myönteisenä Euroopan komission ehdotusta uudeksi biotalousstrategiaksi ja suunnitteilla olevaa Circular Economy Act -aloitetta. Biokaasu ja biokiertolaitokset kiertotalouden ytimessä Biokaasu on konkreettinen esimerkki kiertobiotalouden ratkaisusta. Sen tuotanto perustuu kestäviin biomassalähteisiin, kuten maatalouden sivuvirtoihin, eläinperäisiin jätteisiin, puhdistamolietteeseen, biojätteeseen ja teollisuuden orgaanisiin jätevirtoihin. Biokaasun hyöty perustuu biomassan muuntamiseen uusiutuvaksi energiaksi, mädätysjäännöksen käyttöön ravinteikkaana lannoitteena ja biogeenisen hiilen talteenottoon ilmastotavoitteiden tukemiseksi. Biokiertolaitokset, kuten biokaasu-, kompostointi- ja muut käsittelylaitokset, tukevat maaperän terveyttä, ravinteiden kierrätystä ja ekosysteemien kestävyyttä. Ne mahdollistavat sivuvirtojen ja jätteiden muuttamisen arvokkaiksi resursseiksi, vähentävät riippuvuutta tuontilannoitteista ja fossiilisista energialähteistä sekä edistävät hiilen sitoutumista maaperään ja vähähiilisyystavoitteiden saavuttamista. Integrointi maatalouteen, teollisuuteen ja jätehuoltoon luo synergioita, parantaa energiaomavaraisuutta ja vähentää ympäristökuormitusta. Keskeiset suositukset: 1) Kestävien biomassojen käyttö ja ravinneylijäämien hallinta - Vahvistetaan viljelykierto- ja väliviljelykasvien asemaa CAP:n ympäristöjärjestelmissä. - Lisätään lannan hyödyntämistä biokaasulaitoksissa ja asetetaan alueellisia ravinneylijäämätavoitteita. - Tehostetaan biojätteen erilliskeräystä ja varmistetaan sen hyödyntäminen biokaasu- ja kompostointilaitoksissa. 2) Biokaasun ja muiden biokiertolaitosten käyttöönoton edistäminen - Asetetaan EU-tavoite 100 miljardia m³ biokaasua ja biometaania vuoteen 2040 mennessä. - Yksinkertaistetaan lupamenettelyjä ja digitalisoidaan hallinnolliset prosessit. - Union Database of Biofuels (UDB) toteutetaan käytännönläheisesti, myös pk-toimijoille. 3) Mädätysjäännöksen ja kompostin hyödyntäminen kierrätyslannoitteina - Selvitetään mahdollisuutta asettaa vähimmäisosuus kierrätysravinteiden sisällölle lannoitevalmisteissa. - Nitraattidirektiivi uudistetaan ravinneylijäämäperusteiseksi. - EU:n lannoiteasetus (FPR) päivitetään tukemaan kiertotaloutta ja helpottamaan orgaanisten lannoitteiden käyttöä. 4) Biogeeninen hiili strategiseksi hiilensidontateknologiaksi - Asetetaan EU-tason tavoite biogeenisen hiilen talteenotolle ilmastolain osana. - Määritellään yhteiset sertifiointikriteerit ja sisällytetään vaatimuksia tuotekohtaisiin säädöksiin (mm. Ecodesign). - Julkisia hankintoja hyödynnetään vähähiilisten tuotteiden ja biogeenisen hiilen käytön edistämiseksi. Biokaasu- ja muut biokiertolaitokset tarjoavat monipuolisen ratkaisun Euroopan energia-, ravinne- ja ilmastotavoitteisiin. Ne vahvistavat energiaomavaraisuutta, tukevat ravinteiden kiertoa ja edistävät maaperän terveyttä. Kiertotalouteen perustuva biotalous biokaasu- ja biokiertoratkaisujen avulla on ympäristön ja talouden kannalta kestävä ja strategisesti tärkeä Euroopan tulevaisuudelle.
Read full responseResponse to Evaluation of the Fertilising Products Regulation
19 Sept 2025
The Finnish Biocycle and Biogas Association (FBB) thanks you for the opportunity to provide comments on the EU Fertilising Products Regulation (FPR). General remarks FBB welcomed the 2019 expansion allowing CE marking for composts and digestates (CMC 3, 4, 5; PFC categories). EU recognition of end-of-waste (EoW) status is important, as Finnish legislation does not yet provide it. However, REACH registration makes using recycled materials unnecessarily burdensome; exemptions exist for digestates and composts, but lighter solutions are needed for other circular materials. REACH also adds overlapping administrative work. While FPR offers new EU market opportunities for organic recycling fertilisers, practical requirements and limits are too heavy, particularly for SMEs. In Finland, CE marking benefits do not outweigh costs due to low product prices and limited demand. Fertilisers should continue to be allowed under national legislation, which has long regulated production from sewage sludge, biowaste, industrial by-products, and agri-biomass. Sewage sludge is not included in the FPR; FBB hopes this will be addressed in future revisions of the Sewage Sludge Directive. Permitted input materials FPR excludes established safe components, and the status of animal by-products remains unclear. Narrowly defined inputs limit innovation and disproportionately affect small circular-economy operators. FPR should allow: - Sewage sludge - Forest industry sludges (primary, bio, mixed) and similar industrial by-products (CMC 3, 5, 11) - Biochar or ash (thermally treated biomass) (CMC 4, 3) Sampling, auditing, and Module D1 compliance excessively increase costs. D1 should be simplified towards Module A without full replacement. Product function categories In PFC 1(A)(I) for solid organic fertilisers, limit values for contaminants (zinc, copper) and nutrients are often unachievable without major investment. Products are made from variable waste streams, and plants may lack capacity to upgrade them. Liquid organic soil improvers in Finland, with ~1.5% organic carbon, do not meet PFC 1(A)(II) but should be recognised under organic soil improvers. Labelling requirements, especially for complex mixtures and multilingual packaging, are overly burdensome. Component material categories & ABPR Mesophilic anaerobic digestion at 3740°C without pasteurisation or composting should be recognised under CMC 4 and 5. Current ABPR pasteurisation requirements (70°C, 1h, 12mm) impose significant costs and limit EU market access; Finland allows alternative timetemperature regimes that provide needed flexibility. Analysis requirements Analysis of hexavalent chromium (Cr VI) and PAH16 is costly and limited to few labs. The regulation requires five E.coli and Salmonella samples per batch; a more risk-based, batch-specific approach would reduce unnecessary losses without compromising safety. Conclusion FBB urges the FPR to be made more practical and enabling for SMEs, particularly by easing requirements for compost and digestate, reflecting that EU-wide markets are still developing. This aligns with EU sustainability objectives, including the Farm to Fork Strategy and promoting the use of recycled fertilisers. You can find our more detailed statement in the appendix.
Read full responseResponse to Commission Directive amending Annex III of the Nitrates Directive
16 May 2024
The Finnish Biocycle and Biogas Association (SBB) thank for the opportunity to submit a statement on the rules on the use of certain fertilising materials from livestock manure (RENURE). The wider use of organic fertilisers and nutrients from recycled waste streams will strengthen EU self-sufficiency and food security. It contribute several strategic objectives set by the EU to close the nutrient cycle and promote the health and diversity of agricultural land. Manure is a valuable material whose energy and nutrient content should be utilised efficiently. In Finland, approximately 15 million tonnes of livestock manure is formed annually, the processing of which causes annual greenhouse gas emissions of 0.7 Mt CO2 eq to the agricultural sector. The biogas process should increasingly be seen as an important part of the manure processing chain: it can reduce emissions from manure processing by more than a third in Finland. In the biogas process, methane released from manure is captured and nitrogen emissions into the atmosphere can be reduced. Together with other appropriate measures, anaerobic digestion of manure enables the production of renewable energy, enhances nutrient cycling and the utilisation of nitrogen in manure, and reduces emissions to air and water. In the Commission's proposal, appropriate measures should be taken to allow the use of RENURE fertilisers in livestock manure above 170 kg/N/ha. It should be noted that the proposed methods (ammonium salts (scrubbing salt), mineral concentrates and nitrogen-rich phosphate salts (struvite)) are advanced technologies and are not commonly used in existing farm-size biogas plants. However, centralised biogas plants already produce these products in Finland. SBB would like to point out that the proposed directive is not technologically neutral at present. We do not believe that the directive should lock technologies into just three of the proposed ones. The annex sets out clear criteria for what approved end products should be. It may already be possible to produce such products with other technologies (e.g. with evaporation technology). Technologies are also constantly evolving, especially since there is a clear incentive for their development after the directive changes. The proposal to amend the Directive should, at the very least, leave national competence to approve other possible technologies if the criteria set out in the Annex with regard to product quality are met. SBB considers the change to be highly worthwhile, as the proposal will also encourage the development of technologies and the processing of more refined products from fertilisers. In addition, efficient and appropriate use of RENURE fertilisers can enhance the use of manure-based recycled fertilisers and reduce dependence on mineral fertilisers. In general, it is positive that the the proposal encourages the development of downstream technologies for organic biomasses, the introduction of technologies and the use of fertilising products equivalent to processed mineral fertilisers. More refined recycled fertilising products, which behave similarly to mineral fertilisers in crop production, do not present a risk of release of organic nitrogen under adverse growing conditions and at the wrong time for the plant. It is important that such recycled fertilizers with a longer stage of processing can be used for fertilisation needs in excess of the total nitrogen content of manure in the same way as mineral fertilisers. This possibility would also encourage the production of more refined recycled nutrient products and thus expand their use as a substitute for mineral fertilisers. For this reason, we do not encourage limiting technologies to only certain applications. Finally, we would like to recall the importance of recognising the high content of stable organic carbon in recycled organic fertilizers (including RENURE). Healthy soil tolerates stressors and buffers and balances the water quality of groundwater.
Read full responseResponse to The protection of waters against pollution caused by nitrates from agricultural sources – Evaluation
7 Mar 2024
Finnish Biocycle and Biogas Association (SBB) welcomes the evaluation of the EU's Nitrates Directive, so that the latest information can be assessed whether the Nitrates Directive sufficiently supports the agricultural use of recycled organic fertilizers and promotes the recycling of nutrients and carbon. SBB supports focusing on nutrient balance as well as recognizing the role of organic carbon in soil. Healthy soils tolerate the factors that stress it; It buffers and balances the water quality of groundwater. Organic carbon is an essential part of healthy soil. More attention should be paid to the sustainable use of recycled organic fertilizers and soil improvers (such as compost and digestate), as they can increase the amount of organic matter in the soil, which in turn acts as a buffer for nutrient leaching. Sustainable agriculture is based on healthy soil and nutrient recycling: It is the basis for the EU's Circular Economy Strategy and the Farm to Fork Strategy set out in the European Green Deal. In the evaluation of the Nitrates Directive, it is important to identify the high stable organic carbon content, high organic nitrogen content and lower plant-available nitrogen content relative to total nitrogen in certain organic recycled fertilizers. - Organic recycled fertilizers can distribute the plant-available nitrogen over a longer growing season because of the organic nitrogen. In favourable growing season conditions and with the right fertilization, this can reduce the risk of nitrogen leaching. The nutrients from recycled organic fertilizers and soil improvers should be taken into account when calculating the nutrient balance. The aim should be appropriate nitrogen fertilization and minimizing nitrogen losses rather than minimizing nitrogen use. The evaluation of the Nitrates Directive should pay attention to EU's security of supply, and recognize the role of recycled organic fertilizers and soil improvers in this discussion. The directive should encourage the use of recycled fertilizer products (processed from organic masses) similar to mineral fertilizers, in which case dependence on mineral fertilizers can be reduced. Longer refined recycled fertilizer products, which behave similarly to mineral fertilizers in fields, do not have the risk of releasing organic nitrogen in unfavorable growing conditions and at the wrong time for the plant needs. Such recycled fertilizers with a higher degree of processing should be able to be used for fertilization needs that exceed the total amount of nitrogen in the manure, similarly to mineral fertilizers. This possibility would also encourage the production of further processed recycled nutrient products and thus expand their use as a substitute for mineral fertilizers. It is important that the directive enables the sustainable and adaptable production of recycled fertilizers and practicing agriculture and does not weaken food security. SBB sees it as appropriate to find out the effectiveness of the nitrates directive in meeting the EU's environmental and climate goals: Does it effectively promote sustainable food production in a changing climate and environment and does it take into account new advanced technology? Utilization of new technology, farming techniques and plant varieties can improve nitrogen utilization by plants. In this regard, in the evaluation of the Nitrates directive, it would be necessary to evaluate the appropriateness of covering/covering the sludge tanks on farms when it is a fertilizer product recovered from a biogas plant. Farms must cover their sludge tanks if they receive a fertilizer product from the biogas plant. This brings significant additional costs to farms and can, at worst, prevent participation in the operation of the biogas plant or at least reduce the overall benefit from the biogas plant's fertilizer product and thus the realization of the circular economy.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
8 Nov 2023
Finnish Biocycle and Biogas Association welcomes the Comission Proposal for a targeted revision of the Waste Framework. The Finnish Biocycle and Biogas is a national Association interested in nutrient recycling and biogas promotion and correspond the production of recycled fertilizers. With this paper, we would like to take a position on the proposed amendment to the directive on food waste. According to the waste hierarchy, the prevention of food waste is top priority, but also, it is particularly important to recycle and utilize the nutrients in the food waste. According to Analysis of Seattle, USA, phosphorus and nitrogen in food waste could supply around 10% of nutrients needed for crop production. Along with food waste, the collection and recycling of bio-waste must be increased. Finland likely dont reach the municipal waste recycling target of 55 w% set for the year 2025 (January 1, 2025); set in the waste directive. Therefore, we see that the 65 w% goal set for the year 2035 (January 1, 2035) may also be very difficult to achieve. The national waste act does not set goals for the recycling rate, but in the national waste regulation, the goals for municipal waste are consistent with the waste directive. No legally binding recycling target has been set for bio-waste. Only the national waste plan has set an unofficial goal according to which 65 % of bio-waste will be recycled by 2030 and the recycling of other biodegradable waste will be promoted. Finland will hardly achieve this unofficial goal, because no rising trend in biowaste recycling has been observed; in 2021 the biowaste recycling rate was only 36%. Reasons: Finland has not invested enough in the separate collection of bio-waste. Now, according to the national waste regulation, municipalities are obliged to organize separate collection of bio-waste for all residential properties in agglomerations with more than 10,000 inhabitants no later than July 19, 2024. There are not enough incentives for the separate collection of bio-waste. As the separate collection obligation expands, it will become expensive for some municipalities. A transition phase is now underway. Probably, and we hope that the bio-waste collection rate will increase in the coming years when the separate collection obligation comes into force. If recycling does not become more efficient for bio-waste after 2024, then by 2027 at the latest, more efficient means must be introduced and binding obligations must be considered. Finnish Biocycle and Biogas Association would appreciate the flexibility of the proposal to allow an earlier reference year (than 2020) for the target of cutting food waste. This way, the efforts made before 2020 to curb food waste can be recognized, at least partially. We want to emphasize the importance of monitoring and creating a comprehensive situation assessment. Thus, we see is important to ensure that the data on food waste from different member countries are comparable, as there is no consistent trend data available and the methods and practices of measuring and reporting food waste vary widely among the member states. We appreciate the proposal's requirement for the Commission to reassess the reduction targets in 2027, based on more accurate and consistent data on food waste across different Member States. However, we are concerned about the possible reduction targets for primary production in the reassessment, as the loss of primary production is largely influenced by factors beyond human control, such as weather, diseases and pests. Last, we want to point out, that there is no definition of once edible food waste, which refers to the part of food waste that was once edible, in EU legislation. In the proposal, the Commission mainly refers to food waste, but the proposal does not make it clear in all aspects when it once edible means food waste and when it means food waste. The English terminology for food waste and food waste partly uses the same term "food waste".
Read full responseResponse to Soil Health Law – protecting, sustainably managing and restoring EU soils
30 Oct 2023
Finnish Biocycle and Biogas Association (SBB) welcomes the new proposal of the European Commission for a directive on soil monitoring and resilience. SBB is a national Association interested in nutrient recycling and biogas promotion and correspond the production of recycled fertilizers.We, would like to share the following expert statements and we believe that there is room for improvement on certain aspects addressed by the Soil Monitoring Law. In the proposal soil health certification, the inclusion of anaerobic degradation/digestion as a remediation technique for contaminated sites and the recognition of the prioritization of circular solutions that enrich the organic content as a sustainable soil management principle are positive developments. We cannot overemphasize how important it is to identify sustainable soil management practices (Article 10). The practices of Appendix 3 are very significant in their effectiveness, we hope that attention will be paid to the implementation. We do not object if some obligations are imposed on their use. EU Soil Strategys targets of having all soils in healthy states by 2050 may be challenging to achieve without legally binding goals in the adopted proposal (Article 1); Hence we propose to set legally binding goals. The changes in soil condition towards healthy equilibrium state are usually slow and changes in management practices come up visible on a delay lag of even five or more years. For all that, there should be a clear road map, intermediary binding targets or mandatory national plans to ensure that the soil health objective is reached in due time. We see that soil health certification could increase the interest in sustainable soil management practices such as the prioritization of circular solutions that enrich the organic content and we find it good that the system is voluntary for the landowner. A certification scheme that will be developed in synergy with the carbon removal certification will also bring benefits and new opportunities for landowners, as they can be rewarded by the market for good soil stewardship, and receive financial support or incentives We approach with reservations into the inclusion of harmonized soil descriptors and evaluation criteria which Member States have to use when monitoring soil health. Hence, we see it important that there is enough room for the definition for a healthy soil, so that it allow regionally adapted, based on science, criteria for the indicators. Argument: Soils are very heterogeneous and environmental conditions vary a lot across the EU, even within a small area. Therefore, it can be difficult to find comprehensive indicators that handle, if the soil is really health or not, and if, the indicators are suitable for all soils or not. When setting threshold values (Annex 1), it would be important primarily to take into account the actual effects on the ecosystem. For example, too strict binding threshold values can make it difficult to use organic and recycled fertilizer products, especially in soils where the natural concentrations of a certain element are high for example due to high cation exchange capacity (CEC). We believe that better information on the innovative practices for sustainable soil management and regeneration is essential for Member States. This implies investing in research and various projects to translate knowledge into action. We also see that sustainable management practices should consider the economic impacts of the actions, and that they should not impose excessive costs on farmers who may need to change their machinery. A lot of soil monitoring is already done in connection with the common agricultural policy and with the help of fertility samples, among other things. In the further processing of the proposal, attention must be paid to the fact that the administrative burden on farmers and landowners does not grow beyond control. Data collection must also be of real benefit to the landowners.
Read full responseResponse to Carbon capture utilisation and storage deployment
30 Aug 2023
The Finnish Biocycle and Biogas Association promotes nutrient recycling and the use and development of biogas technology in the society. We welcome the opportunity to provide views on the Industrial Carbon Management call for evidence. Towards carbon management (CM) = CCU+CCS We see that now the European Commission has a stronger focus on CCS than on CCU. We see that all measures leading to reduction of CO2 concentration in the atmosphere, and limiting their further additions are essential to address climate change. The Strategy should include not only actions related to CCS but also to CCU. The innovative use of carbon feedstock could be used for production of materials and fuels. Indeed, the carbon management (CM) from source to emission has the potential to achieve much higher climate mitigation than only addressing it at end-of-pipe, while at the same time providing much-needed carbon feedstock to essential European industries. Besides of its climate benefits, the CCU has a huge business potential in the short, medium and long term. Our proposal: --> to strengthen the role of CCU in the Industrial carbon management EU strategy. Moreover, in order to make it clearer and more concrete, it would be good to set an EU-level target on CCU activities as well. Harmonization and co-operation beyond policies Indeed, we see that all measures leading to reduction of CO2 concentration in the atmosphere, and limiting their further additions are essential to address climate change. Actually, there are already now technical solutions and end-use application available that enables CCU. For instance, there are several investment projects going on in Finland, where the CO2 emissions of waste incineration or similar are planned to capture and to produce methane with the help of hydrogen. The synthetic methane can then be used as fuel in transport or as raw materials for the chemical industry. These end-use applications are already in use and available (compare e.g. hydrogen trucks). We have found out that sector-specific legislation doesnt necessarily recognise the CCU application; now for instance, the CO2-standard EU-regulation of vehicles lays down combustion engine ban for light duty vehicles by 2035, this will also ban the use of synthetic fuels in combustion engines. This piece of legislation can be seen as a legislative barrier to CCU. If same sort of ban is put for the heavy-duty vehicles, it would dramatically harm short- and medium-term business potential of CCU. We see it important that sustainably produced biofuels and synthetic fuels are not banned in road vehicles. Moreover, as mentioned in the background memo, now in the regulation on Net Zero industry in the medium term, only CCS is identified and goals are set for it. Our proposal: -->to ensure that the CCU is taken into account in the sector-specific legislation such as in vehicle CO2-standards. -->to prepare a visual road map that shows the timetable for the introduction of different technical solutions of CCS and CCU in 2025-2050. Clarification of bio-carbon Currently the carbon terminology is non-coherent, which causes confusion. The terminology should be in line with science and standardization. We see it important that the potential of capturing biogenic CO2 from flue gases is fully recognized and prioritized over capturing fossil CO2. The CCU of biogenic CO2 can lead to negative emissions, but fossil CCS cannot lead only to reduced emissions. Now the definition of biogenic CO2 is unclear. For instance, is CO2 from waste incineration classified as biogenic or fossil carbon? We see it contradictory if e.g. biowaste, that should be separately collected based on the Waste directive, is valued differently e.g. in the CCU-context policy and ETS than in the waste legislation. Our proposal: --> to clarify the terminology (bio-carbon, bio-CCU, biogenic carbon etc.). The
Read full responseResponse to Amendment of the EU ETS Monitoring and Reporting Regulation (MRR) in response to the ETS revision/Fit For 55
23 Aug 2023
The Finnish Biocycle and Biogas Association promotes nutrient recycling and the use and development of biogas technology and its knowledge in the society. We would like to provide the following feedback for the European Commission on EU emissions trading system (ETS) update of the rules for monitoring and reporting emissions.
Read full responseResponse to Review of the CO2 emission standards for heavy-duty vehicles
17 May 2023
The Finnish Biocycle and Biogas Association promotes the use and development of biogas and nutrient recycling in the society. We would like to provide the following feedback for the European Commission proposal on the review of emission standards for heavy-duty vehicles. Please find our comments in the file attached.
Read full responseResponse to Initiative on EU taxonomy - environmental objective
3 May 2023
Please find attached our feedback on the EU Taxonomy Delegated Acts.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
24 Apr 2023
The Finnish Biocycle and Biogas Association promotes nutrient recycling and the use and development of biogas technology and its knowledge in the society. We welcome the Circular Economy Action Plan and the aim to contribute to the circular economy through the review of the requirements for packaging and packaging waste. We consider it important that the European Commission has identified a connection between a well-functioning bio-waste bag and the efficiency of bio-waste recycling. What comes to the biowaste bags and compostable plastics in general, we are aware that problems with compostable plastics have been registered both in sorting plants and in composting and anaerobic digestion plants. In the first case, the plastic kind of material is sorted out and send to energy recovery; in the second case, residues and microplastics are found in the final product (fertilizer). The first case is more common. To avoid the problems, it is necessary to: 1. There is a need to develop technical standard to ensure biodegradability of bioplastic in anaerobic treatment process, hence we recommend to enlarge the scope of EN 13432-standard. 2. The packaging waste that may end up to biowaste recycling route should be ensured compliance and certification of industrially compostable and digestated packaging appropriate standards, that should display the way in which they should be discarded. The use of official biodegradable recycling -label is very important with consumers packaging waste. In order to generate innovation, flexibility should be given for biodegradable packaging waste that is recycled via other route than consumerss waste management route. For instance, in the professional use and b2b uses. We are aware that the terminology regarding bioplastics is not established and there are ambiguities in the terms. The words such as ´bioplastics`, ´biodegradable plastic` or ´biodegradable bioplastic´ are in commonly use, but often incorrectly. Terminological challenges concern the entire value chain: packer, consumer, recycler. Hence, we also welcome the Communication on EU policy framework on biobased, biodegradable and compostable plastics. The communication gives a good starting point to start developing the groundings for bioplastics. Without proper terminology, clear recycling instructions and proper testing standard it is not feasible to make product development. For instance, it is not feasible to develop the packing material if its role in the extended producer responsibility vary country by country. We found it important that there is enough flexibility for the market development of biodegradable plastics. There is a risk that the EU legislation limits the market development and innovation even before the basics have been formed.
Read full responseResponse to Carbon Removal Certification
22 Mar 2023
The Finnish Biocycle and Biogas Association promotes nutrient recycling and the use and development of biogas technology and its knowledge in the society. We welcome the ECs proposal for the EU Certification of Carbon Removals Framework. There is a clear need for the framework, and the lack of EU-level framework is holding the development at the member state level. We support the scope of the proposal. It includes permanent carbon removals with technology, carbon farming related to agriculture and forestry, and carbon storage products, such as wood products. One of the key problems with the Commissions proposal is that the proposal does not provide any answers how the certificates will be used. This is holding any larger uptake of the removals. Another major problem with the Commission's proposal is that it does not present how the carbon emissions through the system would be financed. With regard to carbon farming, however, it is clearly pointed out that carbon sequestration in agriculture should be encouraged either through the agricultural financial framework, or through public initiatives or private initiatives. Of course, it is important to ensure that carbon farming is better taken into account in the CAP in the future than it is now the CAP27 is not really pushing for carbon farming. However, the CAP funding alone is not sufficient, other funding mechanisms are also needed to promote carbon farming and tomorrow's coal certification market. Grass and similar soil improvers could be used more to produce biogas and biomethane, which would result in improved soil healthy, biodiversity and carbon sequestration as well as renewable energy being produced(biomethane). Biomethane sales revenue could partially finance carbon farming measures and carbon markets as well. Making this possible it would require, however, that their soil improvement effect and carbon sequestration would be taken into account more comprehensively in the CO2 emission calculations of the renewable energy directive. Now the calculation method takes into account the replacement of mineral based fertilizers nor the impacts on soil healthy. In addition, grass should be clearly classified as an advanced biofuel in the RED2. In this sense, increasing the utilization of grass should be investigated. In general, it is important to ensure that the necessary development measures to enable carbon farming are also carried out in other regulations, such as RED2 and the energy tax directive. The third danger/challenge we see in the Commission's proposal is that the legislative proposal does not seem to recognize the role of organic fertilizer products in carbon extraction and coal farming. In connection with this, it would be important to consider short-cycle biological carbon as part of the certification system. Further work should at least ensure that the climate and natural diversity benefits of organic fertilizer products are taken into account at least among carbon farming activities. In addition, it is necessary to initiate research on the carbon sequestration effects of microbial activity and the ability of vibrant soil to hold bound carbon and additionally bind more carbon. In addition, we would like to bring to your attention that we consider it very important that in the Commission's proposal the means of carbon removal should at least be neutral with other sustainability goals. Other sustainability goals include, for example, the protection and preservation of natural diversity and the promotion of the circular economy. We consider it important that the draft regulation itself ensures that the regulations do not create too burdensome administrative procedures for small operators, such as farmers. Finally, we would like to point out that the Commission's proposal only provides the basic pieces for the formation of legislation. Much remains to be done in delegated acts. It is important that stakeholders are included in further work as well.
Read full responseResponse to Revision of the Urban Wastewater Treatment Directive
14 Mar 2023
The Finnish Biocycle and Biogas Association promotes nutrient recycling and the use and development of biogas technology and its knowledge in the society. We welcome the ECs proposal for a revised Urban WasteWater Treatment Directive to bring the objectives of the Directive adopted in 1991 up to date. Anaerobic treatment of sewage sludge is a well-functioning treatment technology and is widely used in Finland in connection with medium-sized and large wastewater treatment plants. Article 11 It is important for the directive to take into account the different utilization possibilities of biogas. Biogas produced out of sewage sludge is not always utilised at the WWTP. Biogas of the sewage sludge can also be used to produce district heat or to upgrade it to biomethane to be used as industrial and traffic gas (compressed or liquefied biomethane). With regard to anaerobic treatment of sludge, it is also very important to also take into account those solutions in which sludge processing is outsourced and the produced energy is used outside the WWTP. Outsourcing sludge processing can make sense from an economic and environmental point of view, the solutions depend also on local conditions (demand and supply of energy; ownership structure of the municipality, etc.). Outsourced sludge treatment enables the operation of a larger biogas plant, where pressurized or liquefied biomethane can be produced. More sophisticated nutrient recycling solutions are also possible in the bigger plants. In 2022, there is a total of 19 biogas plants in Finland that only process sewage sludge. Moreover, in some places the sewage sludge is also treated together with, for example, biowaste. Article 20 Nutrient recycling is another important issue. We support that it is included in the proposal. However, more detailed matters are only defined as a delegated act. it is also important to consider the cost effects of delegated regulations.
Read full responseResponse to Update of list of sustainable biofuel feedstocks
22 Dec 2022
The European Commission's proposal to amend Annex 9 of the renewable directive as a delegated act is problematic in many ways. According to Article 28, the Commission is empowered to adopt delegated acts in accordance with Article 35 to amend the list of raw materials set out in Parts A and B of Annex IX to add, but not remove, raw materials from the list. Now the Commission is actually proposing additions to the Part A and Part, which in practice will bring changes to Part A. In Finland, almost all inputs that the commission proposes to be classified as category B belong now to Part A. The proposal would make a significant change in the classification of several inputs in Finland, which would have an impact on the business of existing biomethane producers and partly also on planned facilities, especially regarding facilities that process industrial side streams. In our view, the Commission exceeds its powers with regard to this delegated act. The Commission's proposal has an impact not only on energy, transport and climate legislation, but also on agricultural financing, fertilizers, waste and environmental protection matters. The proposal is in many respects is in conflict with the REPowerEU, where biomethane production is to be increased. Our recommendations: All inputs classified as waste should belong to category A. Biomethane production, where also recycled nutrients and fertilizer products are produced, should be seen as advanced technology. The term "Fit for feed and food use" shall be replaced by "Fit for feed and food use in a feasible way", which will better enable consideration at the member country level. "Fit for feed and food use" is problematic because it increases bureaucracy and room for interpretation. You should also not go for a batch-by-batch review. Classification as waste should be done in a context other than RED2, such as environmental permit, etc. A transition period of at least five years is given for the changes, which can ensure adaptation of operations. If new items are added to the B-part, then also the limit value of 1,7 % needs to raised up. Member countries must have sufficient decision-making power, because geographical factors plays an important role in agricultural and food production issues. The amendments regarding the by-streams of the food industry are worrying. The directive should not define inputs at too precise a level. This ensures that the member countries have sufficient space when implementing the directive. This ensures that national, even regional specificities, can be taken into account. Regional special features include, for example, the length of transport distances, length of growing season, special features of agriculture and the structure of industry. EU-level development work will be launched to define the hierarchy of use of industrial by-streams, where food and energy security and related regulations will be examined. Defining the waste is an essential measure. It is necessary to define the use of mass flows in accordance with the waste hierarchy, also for mass flows suitable for feed.
Read full response24 Oct 2022
Finnish Biocycle and Biogas Association welcomes the proposal to determine the end point in the manufacturing chain for certain products that can be used as organic fertilizers and soil improvers. We would like to provide the following comments.
We agree that the end point in the manufacturing chain is reached at the end of the composting and anaerobic digestion process on an approved plant in accordance with Article 24 (1) of the Regulation (EC) 1069/2009 after the necessary sanitation has been proved and where the compost and digestate are placed on the market as organic fertiliser or soil improver. However, because compost and digestate as component materials are produced in approved plants in accordance with Article 24 (1), point (g) of the Regulation (EC) 1069/2009, we ask to include this in Article 5 of the draft delegated regulation as well.
But with regard to Annex V of Regulation (EU) 142/2011 (required transformation parameters) we see an inconsistency between the possibility to place compost or digestate on the market according to the Fertilising Products Regulation (EU) 2019/1009 and the Animal by-products Regulation (EC) 1069/2009. According to Annex V of Regulation (EU) 142/2011 Section 2, point 4,’Operators may place on the market digestion residues and compost, which have been produced according to parameters which have been authorised by the competent authority:
(a) in accordance with point 1;
(b) in accordance with points 2 and 3, only within the Member State where those parameters have been authorised.
That means in case (a), which refers to point 1 of Section 2 where alternative transformation parameters for biogas and composting plants can be validated according to the harmonised model and authorised by the competent authority, the trade of compost/digestate is not limited to the Member State itself, which signifies that the same level of safety is acquired than the standard transformation parameters. The inconsistency lies within the fact that (treated) animal by-products within the scope of ABPR are allowed as fertilising products on the entire European market in terms of safety, but they are ruled out by the EU FPR because the possible treatment parameters are narrowed down. Therefore, we call the Commission to allow alternative treatment processes with comparable conditions than the standard treatment parameters to prevent risks to public and animal health which are validated and allowed by the competent authority by adding Section 2, point 1 of Chapter III of Annex V of Regulation (EU) No 142/2011 to Article 3 (b) and (c) of this delegated regulation.
The proposed provisions in article 4.2 lays down a requirement that products must be packed in bags of a maximum of 50 kg. We see that this doesn’t makes any sense in terms of professional farming, where several tons of the products are handled. Moreover, the package size will be unnecessary regulatory obstacles in the way of use of organic residues as fertilizers or soil improvers.
Read full responseResponse to Review of the CO2 emission standards for heavy-duty vehicles
14 Mar 2022
The Finnich Biocycle and Biogas Assocation welcomes the initiative to review current CO2 emission standards for heavy-duty vehicles and to set more ambitious emission reduction targets for such vehicles. We also want to stress that EU legislation, including CO2 emissions standards regulation, should be built on the life-cycle-based approach such as well-to-wheel or life-cycle analysis on climate emissions. Such a life-cycle approach is used in the 55-package of the European Commission (see FuelEU Maritime and RefuelEU Aviation). There are clear research-based reasons to do it.
Under the current vehicle regulation, a manufacturer's compliance with its specific emission target is assessed only against the average tailpipe CO2 emissions of its fleet. We are very critical of this tailpipe approach. The tailpipe approach is not technological neutral. It also misses its primary objective: to guide towards reduced climate emissions and away from fossil fuels. It is not recognizing the great contribution in emissions reduction achieved using biomethane and other advanced renewable fuels.
The 55-package of the Commission gives several legislative proposals for transport sector. The Commission has not provided proper impact assessment of the total costs. We see it very important to understand the total costs of not only in the review of emission standards for heavy-duty vehicles but also in other initiatives given in 2021 and 2022 by the Commission. It is crucial, that the proposal ensures cost-effective emissions cuts in the heavy-duty vehicles – this can be ensured only by following technology neutral approach. The sustainable biofuels are crucial to be in the measures to reduce the CO2-emissions from the road transport. This also improves energy self-sufficiency of the member states.
Finally, we would like to remind you that the policy must be consistent. Now the renewable energy directive obliges the member states to increase the use of renewable fuels in transport. The directive also encourages the production of renewable energy. The Commission recent communication on the REPowerEU proposes to set a target for biomethane production (35 bcm by 2030) to cut dependence on Russian gas. We welcome this long-awaited initiative. At the same time, however, vehicle CO2-regulations hamper the use of biomethane, for example. We see this as a serious legal barrier for the use of biomethane in vehicles. With the tailpipe approach sustainable alternatives such as biomethane will unfortunately be excluded from the market and denied the opportunity to contribute to the mitigation of climate change. That would be in sharp contrast to scientific findings (e.g. the Joint Research Centre (JRC) of the European Commission: ttps://publications.jrc.ec.europa.eu/repository/handle/JRC121213 ) showing that, from all combinations of fuel/energy carriers and powertrains explored, biomethane represents one of the absolute lowest greenhouse gas intensive routes.
Read full responseResponse to Count your transport emissions: CountEmissions EU
15 Dec 2021
Finnish Biocycle and Biogas Association finds it important to develop common framework to calculate and report transport-related greenhouse gas emissions. We acknowledge that the work is demanding and laborious. For instance, the JRC has developed the PEF method for a decade.
More relevant question is how to use the method. In our opinion, first the method needs to developed and then can be seen where it can be used. The rules need to be detailed enough and they need to be technological neutral. As important is to have valid data. Without good rules and data, the results of the calculation are not precise and cannot be used in general, certainly not in legislative obligations.
However, somebody might ask, how much the customer can choose anyway because there is so much legislation in place already. Indeed, there are several policy instruments existing to manage the CO2-emissions of fuels and vehicles: RED2 for the renewable energy (life-cycle; CO2 and other environmental impacts), CO2-standard for vehicles (use phase; just CO2), ETS for maritime and road transport (use phase; just CO2), energy tax directive (production and use phases; CO2 and other environmental impacts). However, who has the control over the whole transport? In order to have zero-emission transport, there is need to have the overall control on the emissions over the whole life cycle of the product/service. At the moment, there is not a comprehensive management of the transport emissions, but the legislation is being developed and split between different DGs.
METHDOLOGICAL ISSUES:
• CO2-footprint is important, but also other environmental impacts are relevant. For instance, losses in biodiversity is big challenge globally. These should not be neglected and should be included in the work.
• It is important that the method includes the real emissions from cradle to grave. We support life-cycle-thinking, and in our opinion LCA is the most comprehensive way of assessing environmental impacts of products and services. According to our understanding, the CO2-footprint include
• Methodological solutions and assumptions that are made in the calculations have big impact on the results. While biomethane does emit CO2, the GHG protocol sees it as biogenic (fast cycle) CO2, which is different from fossil CO2. Also, decisions such as how to allocate emissions between by-products are important for biomethane. Biomethane production is closely linked to the waste management and nutrient recycling, so in most of the cases the preliminary purpose is not to produce only energy. For instance, digestate can be used to revitalize the soil and in turn, this minimises the use of mineral fertilizers (also called chemical fertilizers), and therefore further avoids CO2 emissions. This type of biomethane production can lead to carbon negative emissions.
DATA: It is important to use good data in the calculation. What comes to the biogas and biomethane, it is not recommended to use only one reference value in the calculation in the EU, because there are lots of variations in the input materials and systems in different member states. For instance, biomethane (fuel) produced out of manure can have negative CO2-emissions, as biowaste based biomethane CO2-emissions are about 80-60% lower compared to fossil fuels.
EXPERTISE: JRC has done a comprehensive work on assessing CO2 emissions from WtW approach. The JRC has also done good work with developing PEF-method. Moreover, it is important to include stakeholders in the development work.
Read full responseResponse to Policy framework on biobased, biodegradable and compostable plastics
26 Oct 2021
The Finnish Biocycle and Biogas Association welcomes the Commission’s initiative to develop a policy framework on biobased, biodegradable and compostable plastic to clarify their role in the transition to a carbon neutral economy and a toxic-free circular economy.
Finnish Biocycle and Biogas Association together with several Finnish biodegradable (bio)plastic producers and waste management companies have been assessed the bottlenecks of the recycling of biodegradable plastic. This is a horizontal issues, and the co-operation along the whole supply chain is needed: product & package producers, retailers, consumers (recycling), waste management companies, and the next life-cycle of the materials.
Now most of the biodegradable plastic among the bio-waste (such as bio-waste bags) is finally being incinerated rather than recycled, because the separation technics at the AD plants cannot make difference between fossil-based plastic and biodegradable plastic. Moreover, a waste management company is not willing to take a risk that there would non-biodegradable plastic in the fertilizer product. All these lead to the fact, that the recycling of biodegradable plastic is not happening or it is ineffective.
One of the problem is that there is not an official standard defining biodegradable requirements for plastic in anaerobic waste treatment. Now EN 13432 (Packaging: Requirements for packaging recoverable through composting and biodegradation) applies only to industrial compost plants. The increased volumes of separately collected municipal bio-waste in the Member states is expected to lead to growth in volumes also in the AD plants.
One of the problem that is not mentioned in the roadmap is potential negative effect on companies' willingness to invest. Now the companies (producers, users and recyclers of these new materials) are facing unclear legislation and remarkable differences in the implementation and interpretation between the member states.
What comes to the waste legislation, there are also challenges at the moment. e.g. a package producers or packager cannot recommend in the package, how to recycle the thing, because it is not necessarily responsible for organising the waste management. Typically a municipality is responsible in organising the collection and recycling of municipal waste, producers are responsible in organising the recycling of packages etc.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
18 Dec 2020
The Finnish Biocycle and Biogas Association (SBB) welcomes the efforts to engage the financial sector to support the European Green Deal and to invest in the transition to a carbon neutral economy. Despite the fact that the taxonomy initiative has taken notable improvements during its development phase and compared to the initial TEG report, we are still highly concerned about its actual capabilities of advancing carbon neutral circular economy in the EU.
Our main concerns are:
1. Categorizing highly sustainable renewable energy such as biomethane with multiple positive externalities as a ‘transitional’ activity is not justified.
2. Additional sustainability requirements on bioenergy are not needed, because current sustainability criteria are introduced already by the RED II. It is a necessity to streamline the taxonomy to be coherent with other union legislation.
3. The draft taxonomy qualifies conversion/retrofit of existing natural gas networks to 100% of hydrogen or other low carbon gases but the term ‘low-carbon gases’ has not been defined. At least all renewable gases should be under the scope to support a truly sustainable transition of the gas sector but at the moment it is not explicitly mentioned whether connecting plants producing renewable methane qualify sustainable. It is a necessity to include biomethane in the scope in order to advance the development of energy and material integration in Europe. Biomethane is renewable gas that is widely available already now. It takes time before other renewable gases are widely in use. The biomethane paths the way to the other renewable gases, because the gas infrastructure can be used.
4. With regard to the transport sector, we propose that biomethane is clearly categorized for the ‘green’ category mitigating climate change. As on the LCA-basis, bio-CNG and bio-LNG can reduce emissions by more than 100% (JEC 2020) and biomethane plays a key role preventing the EU’s methane emissions in waste management and agriculture. The choice of 100% electrification will not result in decreased CO2 emissions by 2030, because the European electricity supply will most probably remain for the next 10 years – to a large extent fossil. Public transport vehicles running on biomethane and fleets of public authorities using biomethane should also be included, as done already in the Clean Vehicles Directive 2019/1161; consequently, also bio-CNG/bio-LNG refuelling points/stations should be included in the taxonomy.
5. Regarding the Sea and coastal freight water transport, we strongly object any CO2 emission reduction targets based on the tailpipe approach. Energy efficiency can be improved in different ways while no technology should be excluded contributing to the emissions savings in the sector: bio-LNG is clearly one of the few viable options that are available today. It can be used in existing LNG engines with little, or no modification and transported, stored and bunkered in ports utilising existing LNG infrastructure. Consequently, it can be used seamlessly as a drop-in fuel.
It is important to recall the wider cross sectorial role of biomethane that can help in reduce emissions to air, water and land from various sectors namely agriculture, waste management, energy production, industry and transport. Biomethane production is at the heart of an efficient circular economy: it is the best way to recycle organic waste, to produce valuable renewable gas and biofertilizers. The potential of biogas and biomethane has pointed out in the several policy papers published by the European Commission in 2020 such as in a Farm-to-Fork strategy, EU methane strategy and a new Circular Economy Action Plan. In Finland, nutrient recycling and biogas/biomethane are very much linked to the decarbonizing activities of agriculture, transport, energy production, industries and waste handling sectors. Finland has set a target to be carbon-neutral by 2035.
Read full responseResponse to Revision of the CO2 emission standards for cars and vans
26 Nov 2020
Finnish Biocycle and Biogas Association welcomes the efforts of the European Commission to revise the existing legislation to achieve a new 2030 target and the climate neutrality objective by 2050. Despite all the current efforts at the EU level, the greenhouse gas emissions are not decreasing in the transport sector.
The revision of CO2 vehicle standards is very crucial to ensure a fast, safe and affordable transition to smart and sustainable mobility. As mentioned in the roadmap, the CO2 vehicle standards have proven to be an effective policy tool but without further policy intervention, emissions from road transport are not projected to meet the targets set. It is clear that leveraging on the CO2 emissions reduction only at tailpipe level has not been sufficient enough to ensure the shift to carbon neutral mobility.
One of the bottlenecks is that the current CO2 vehicle standards on passenger vehicles and vans prevents Europe from exploiting the full potential and advantages of biomethane in transport. This is entirely inconsistent with the scientific findings, which are clear: biomethane represents one of the absolute lowest greenhouse gas intensive options applicable to decarbonization of road transport. The current CO2 emission standards are also contradictory to the revised Renewable Energy Directive setting a favourable framework for the uptake of biomethane in transport.
The revision aims at increasing interlinkages between energy and mobility sectors. However, we see that this will not happen unless the role of biomethane is strengthen in the context of the revision. The potential of renewable gases has been recognized widely in the EU policies and at national levels. Biomethane is renewable gas that is widely available already now. It takes time before other renewable gases are widely in use. The biomethane paths the way to the other renewable gases, because the gas infrastructure can be used.
It is also important to recall the wider cross sectorial role of biomethane that can help in reduce emissions to air, water and land from various sectors namely agriculture, waste management, energy production, industry and transport. Biomethane production is at the heart of an efficient circular economy: it is the best way to recycle organic waste, to produce valuable renewable gas and biofertilizers. The potential of biogas and biomethane has pointed out in the several policy papers published by the European Commission in 2020 such as in a Farm-to-Fork strategy, EU methane strategy and a new Circular Economy Action Plan.
We call on the European Commission to eliminate the regulatory obstacles by taking three constructive measures, all of which fit within the European Green Deal Framework:
• INCENTIVES FOR OEMS: The carbon credits for gas vehicles can be applied in all member states by adding a following sentence to the article 5 article of the Regulation (EU) 2019/631: [The average TTW emissions of new gas passenger car are calculated as 50 g CO2 /km, but the TTW emissions needs still be under 95 g CO2/km.]
• INCENTIVES FOR BIOMETHANE PRODUCERS: setting a target for the share of renewable gas (transport) used in the EU by 2035 or other measurement to fasten the development. The target could be set e.g. in the context of the RED 2 revision or the fuel quality directive revision. The average share of renewable gas in the EU is 17%, in Sweden 94% and in Finland 58%.
• FURTHER INTERGRATING BIOMETHANE TO THE ENERGY AND RESOURCE SECTORAL INTEGRATION: By 2025 the WTW approach is taken into account in addressing eco-efficiency of PCs, LDVs and HDVs. / OR by 2030 a having a new mechanism such as a voluntary CO2-crediting mechanism.
Finnish Biocycle and Biogas Association members produce 70% of Finnish biogas, own 85% of transport gas distribution stations and are responsible for more than 50% of recycled nutrient production in Finland.
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