Bioenergy Association of Finland welcomes the overall aim of the Biotech Act II to strengthen Europe’s bioeconomy and industrial competitiveness.
The initiative should build on clear framework conditions for sustainable bio-based value chains, support investment certainty, and accelerate the deployment of bio-based solutions that contribute to economic growth, decarbonisation, circularity, and European resilience.
We strongly advise the Commission to ensure that the Biotech Act II avoids unnecessary regulatory duplication. It should enable additional sustainable feedstock mobilisation across the wider bioeconomy.We call on the Commission to consider the following points:
- Sustainability and verification should be based on existing EU frameworks
We highlight the need for consistent and stable approach to sustainability verification.
Any sustainability requirements related to bio-based content, biomass sourcing, or market incentives should be based on the existing sustainability and verification standards outlined in the Renewable Energy Directive (RED III), particularly Articles 29 and 30.
RED III already sets out criteria for biomass sourcing, biodiversity protection, land-use safeguards, forest regeneration, carbon stocks, greenhouse gas performance, and traceability. These provisions apply to both EU and imported feedstocks and are supported by recognised certification systems and verification methodologies.
Therefore, the Biotech Act II should avoid creating parallel sustainability systems or additional reporting frameworks.
- A pragmatic approach to biomass use and cascading is needed
We support the efficient use of biomass throughout the bioeconomy. We encourage maximising the value of biomass whenever that is technically, environmentally, and economically feasible.
However, policy frameworks must avoid rigid assumptions concerning the allocation of biomass among its various end uses. Biomass feedstocks vary in quality, regional availability, logistics, sustainability characteristics, and end uses.
The most suitable use of biomass is context-specific. Residues, co-products, and by-products from sustainable forest management, agriculture, and industrial processes can contribute to multiple value chains, including renewable energy.
Bioenergy plays a complementary role in today’s market-based biomass allocation. Residues and by-products flow naturally into bioenergy, enabling circular, efficient value chains across forestry, pulp and paper, sawmills, and heating networks. Next in line are utilisation of biogenic CO2 and biochar.
Finland’s progress in decarbonisation of both power and heat/cooling over the last 10-15 years has been possible with a market-based biomass allocation, which also protected Finland against the worst hikes in energy prices after 2021. Nevertheless, entry of new technologies, such as electric boilers, waste heat utilisation and heat pumps has taken place.
Therefore, a pragmatic approach to biomass cascading is essential: one that promotes efficient use of biomass without imposing inflexible hierarchies that overlook regional circumstances, market realities, or the broader need for decarbonisation and energy security.
- Existing biomass supply chains should support wider bioeconomy deployment
Sustainable biomass value chains already build a scalable basis for feedstock mobilisation, certification, logistics, and market access throughout Europe.
To successfully scale up sustainable bio-based pathways, we need not only innovation but also effective supply chains, and stable regulatory frameworks. Mobilising even more versatile sustainable biomass – along the impact assessments of ie Climate Target 2040 – requires coherent regulations and efficient certification and logistics.
Policies must support the complementary deployment of bio-based applications without creating unintended barriers that might decrease the availability of sustainable biomass or undermine established value chains.