Bioenergia ry – the Bioenergy Association of Finland – welcomes the initiative to evaluate the Renewable Energy Directive for the next decade.
The EU has recently agreed a new binding climate target for 2040 in the EU Climate Law. In the coming months, several legislations will be introduced to implement this target. As a general principle for decarbonisation, the focus should be on decreasing fossil emissions in the EU. Additional renewable energy, improvements in energy efficiency, growing carbon capture and technical carbon sinks should all be considered key tools as the EU advances toward its 2040 climate target.
We note that based on the recent assessment from the EEA, the EU is likely not on track to meet the current 2030 targets for renewable energy. The renewable energy share was at 25.4% in 2024 and the increase from 2023 was slightly lower than the average annual pace of growth recorded in the previous five years. Meeting the minimum EU target for renewable sources of 42.5% by 2030 would require doubling the rates of renewables deployment seen over the past decade, and a deep transformation of the European energy system.
Despite the slow RES progress the EU is close to being on track to cut its greenhouse gas emissions by 55 % by 2030 (current estimate with additional measures is 54 %). Emissions have particularly decreased in the EU Emissions Trading System (EU ETS) sector. This highlights the role of the EU ETS as a central instrument for driving cost-effective decarbonisation and investment decisions and supports a stronger focus on emissions outcomes rather than technology-specific deployment metrics.
The 2040 climate target will be further implemented with binding sub-targets for emission cuts backed by compliance systems in emissions trading and other sectors. In the current difficult competitive environment of the EU, the main principles in the design of these binding cuts should be technology-neutrality, cost-effectiveness and flexibility. All cost-efficient low- and zero-emission solutions should be allowed on equal terms.
Therefore, the Bioenergy Association of Finland believes that once Member States have achieved a minimum level of renewable energy deployment and energy efficiency (e.g. the 2030 target), Member States and companies should have greater flexibility in choosing subsequent measures to reduce emissions and increase carbon sinks. Progress monitoring should increasingly focus on GHG emissions and removals in the agreed sectors – not on secondary indicators, such as the shares of different energy sources or the total amount of energy saved. Such an outcome-based approach would improve investment predictability, support energy system integration and help safeguard the competitiveness of European industry.
RED3’s built-in re-evaluation clauses within articles 3 and 29 for bioenergy are non-applicable as the assessment of the actual functioning of the criteria will not be possible, since they have not been implemented in most member states. For this reason, the evaluation cannot be done properly and should instead be postponed to 2028-2029.
In the spirit of streamlining the Union regulation, we propose to re-extend the scope to 20 MW, aligned with the EU ETS. For biomethane plants, the threshold could be 5 MW. The vast majority of biomass is used in plants larger than 20 MW, demonstrating the sustainability of smaller plants is inefficient, and fuel procurement is anyhow typically done locally1. We also propose that the changes to the sustainability criteria for bioenergy (Article 29) are effectively frozen until 2040.
Most of the sector-specific sub-targets could be removed. We do, however, support sub-targets for transport, including maritime and aviation, as we need to see more rapid progress in that sector.